ML25273A369
| ML25273A369 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 09/30/2025 |
| From: | Lighty R, Polonsky A Long Mott Energy, Morgan, Morgan, Lewis & Bockius, LLP |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57500, ASLBP 25-991-01-CP-BD01, 50-614-CP | |
| Download: ML25273A369 (0) | |
Text
CONTAINS SECURITY RELATED INFORMATION - SUBJECT TO PROTECTIVE ORDER UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
LONG MOTT ENERGY, LLC (Long Mott Generating Station)
Docket No. 50-614-CP September 19, 2025 QRQSXEOLFYHUVLRQ
6HSWHPEHU SXEOLFYHUVLRQ
LONG MOTT ENERGY, LLCS ANSWER TO SAN ANTONIO BAY ESTUARINE WATERKEEPERS HEARING REQUEST SUPPLEMENT RYAN K. LIGHTY, Esq.
ALEX S. POLONSKY, Esq.
MORGAN, LEWIS & BOCKIUS LLP Counsel for Long Mott Energy, LLC CONTAINS SECURITY RELATED INFORMATION SUBJECT TO PROTECTIVE ORDER
CONTAINS SECURITY RELATED INFORMATION - SUBJECT TO PROTECTIVE ORDER ii TABLE OF CONTENTS I.
INTRODUCTION............................................................................................................. 1 II.
BACKGROUND............................................................................................................... 3 A.
AIA-Related Requirements.................................................................................... 3 B.
The CPAs AIA Description.................................................................................. 5 III.
THE PETITION SHOULD BE DENIED BECAUSE WATERKEEPER STILL HAS NOT PROPOSED AN ADMISSIBLE CONTENTION.......................................... 5 A.
Contention Admissibility Requirements................................................................ 5 B.
Contention 5 (AIA) Is Inadmissible....................................................................... 6 1.
Waterkeeper Improperly Challenges ((
))SRI...................................................................................................... 7 2.
Waterkeepers ((
))SRI Arguments Are Legally and Factually Unsupported, Out-of-Scope, and Fail to Raise a Genuine Material Dispute......................................................................................... 9 3.
Waterkeepers Footnote 7 Provides No Basis for a Contention.............. 12 IV.
CONCLUSION................................................................................................................ 13 CONTAINS SECURITY RELATED INFORMATION SUBJECT TO PROTECTIVE ORDER
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I.
INTRODUCTION Pursuant to 10 C.F.R. § 2.309(i)(1) and the Atomic Safety and Licensing Boards (ASLB or Board) Initial Prehearing Order,1 Long Mott Energy, LLC (LME) submits this Answer to San Antonio Bay Estuarine Waterkeepers (Waterkeeper) Supplement (Supplement)2 to its August 11, 2025 Hearing Request and Petition to Intervene (Petition).3 In its Petition, Waterkeeper requested a hearing and proposed four contentions (Contentions 1 through 4) purporting to challenge certain publicly available information in LMEs Construction Permit (CP) Application (CPA).4 The CPA requests approval from the U.S. Nuclear Regulatory Commission (NRC) to construct a new reactor facility known as the Long Mott Generating Station (LMGS) in Calhoun County, Texas, under 10 C.F.R. Part 50.5 In its Supplement, Waterkeeper proposes an additional contention (referred to herein as Contention 5) asserting a challenge to certain non-public Sensitive Unclassified Non-Safeguards Information (SUNSI) in the CPA. Specifically, Contention 5 seeks to challenge Section 3.12 of Preliminary Safety Analysis Report (PSAR), which provides certain information related to the CP-stage Aircraft Impact Assessment (AIA) for LMGS.
1 Memorandum and Order (Initial Prehearing Order) at 2-3 (Aug. 28, 2025) (ML25240B507).
2 San Antonio Bay Estuarine Waterkeepers Second Corrected Supplement to Its Petition to Intervene and Request for Hearing Based on Sensitive Unclassified Non-Safeguards Information (Aug. 29, 2025)
(ML25241A192, non-public) (Supplement). A redacted version of the Supplement is publicly available (ML25252A405). Waterkeeper originally filed the Supplement on August 25, 2025, but it did not comply with the SUNSI marking requirements in the Boards Protective Order. Waterkeeper re-filed a corrected Supplement on August 27, 2025, but it also did not comply with those requirements. Waterkeeper re-filed the second corrected Supplement referenced here on August 29, 2025, and it was subsequently modified at the Boards direction to add protective markings to the first page. See Licensing Board Memorandum and Order (Regarding Protective Order Noncompliance) (Sept. 4, 2025) (ML25247A219).
3 San Antonio Bay Estuarine Waterkeepers Petition to Intervene and Request for Hearing (Aug. 11, 2025)
(ML25223A335) (Petition).
4 Letter from E. Stones, LME, to NRC Document Control Desk, Submittal of the [LME] [CPA] for [LMGS]
(Mar. 31, 2025) (Package ML25090A057 (public version)) (CPA).
5 A separate operating license application, under 10 C.F.R. Part 50, is expected to be submitted in the future but is not within the scope of this proceeding.
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In its Answer to the Petition, LME recommended that the Board DENY the Petition because Waterkeeper provided insufficient information to demonstrate standing,6 and because Contentions 1 through 4 are inadmissible,7 both of which are independent grounds requiring denial of the Petition.8 As detailed below, the Supplement does not alter that recommendation because Contention 5 also is inadmissible.
Contention 5 is rooted in fundamental errors that preclude its admissibility. For example, Waterkeeper continues to conflate regulatory requirements for CP applications with those for operating license (OL) applications. The respective requirements are materially different and Waterkeeper does not acknowledge the distinction. Waterkeeper demands satisfaction of the latter requirements even though only the former requirements are applicable to the CPA. For that reason, its claims fail to raise a material dispute with the CPA.
Furthermore, Waterkeeper fundamentally misconstrues those requirements. Licensing applications need only include ((
))SRI Thus, because Waterkeeper improperly challenges ((
))SRI Contention 5 is immaterial, beyond the scope of this proceeding, and does not demonstrate a material dispute with the CPA. For these and other reasons detailed below, Contention 5 should be rejected as inadmissible.
6
[LME]s Answer to [Waterkeeper]s [Petition] § III (Sept. 5, 2025) (ML25248A335) (LME Ans. to Pet.).
7 Id. § IV.
8 10 C.F.R. § 2.309(a) (requiring both standing and at least one admissible contention to grant a hearing).
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II.
BACKGROUND High-level summaries of the CPA, the NRCs regulatory framework for CP reviews, and the procedural history of this case are provided in LMEs Answer to the Petition,9 and are incorporated-by-reference here. However, background specific to the NRCs AIA-related requirements, and the CPA content addressing those requirements, is provided below.
A.
AIA-Related Requirements In 2009, the Commission concluded that it would be prudent for nuclear power plant designers to consider the potential effects of a hypothetical aircraft impact on the ability of the plant to cool the reactor core and spent fuel.10 Accordingly, the Commission conducted a notice-and-comment rulemaking to impose certain corresponding requirements.11 Those requirements include the NRCs license application content provisions at 10 C.F.R. § 50.34(a)(13) and (b)(12),
which mandate, respectively, that CP and OL applicants shall submit the information required by 10 CFR 50.150(b) as a part of their [PSAR/FSAR]. 10 C.F.R. § 50.150(b), titled Content of application, explains that those respective PSARs and FSARs:
must include a description of:
(1) The design features and functional capabilities identified in paragraph (a)(1) of this section; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of this section meet the assessment requirements in paragraph (a)(1) of this section.
9 Id. § II.
10 See generally Consideration of Aircraft Impacts for New Nuclear Power Reactors; Final rule, 74 Fed. Reg.
28,112 (June 12, 2009) (AIA Rule).
11 Id. at 28,112.
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The term paragraph (a)(1) refers to a separate requirement in 10 C.F.R. § 50.150(a)(1),
titled Assessment, which requires that applicants:
shall perform a design-specific assessment of the effects on the facility of the impact of a large, commercial aircraft. Using realistic analyses, the applicant shall identify and incorporate into the design those design features and functional capabilities to show that, with reduced use of operator actions:
(i) The reactor core remains cooled, or the containment remains intact; and (ii) spent fuel cooling or spent fuel pool integrity is maintained.
In the Statements of Consideration for the final rule promulgating these requirements, the Commission expressly distinguished the assessment, required by 10 C.F.R. § 50.150(a)(1), from the description, required by 10 C.F.R. § 50.150(b). Specifically, the Commission explained that the NRCs evaluation of the description in a CP or OL application will be separate from its determination regarding the adequacy of the assessment; and it cautioned that:
the adequacy of the impact assessment may not be the subject of a contention submitted as part of a petition to intervene under 10 CFR 2.309.12 Furthermore, as to the descriptions required to be provided in CP and OL applications, the Commission explained that it would apply separate sufficiency standards for each stage:
The final rule is being applied to applicants at both construction permit and operating license stage because it is not until the operating license stage that the applicant is required to provide the NRC with its final design. The NRC can issue a construction permit based on preliminary design information. Therefore, the NRC believes it is necessary to require applicants to perform the aircraft impact assessment at both stages and to include the required information in both applications based on the level of design information available at the time of each application.13 12 AIA Rule, 74 Fed. Reg. at 28,120.
13 Id. at 28,126. See also id. at 28,115 (stating the same with slightly different wording).
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B.
The CPAs AIA Description LME addresses the requirement to provide an AIA Description in its CPA at PSAR Section 3.12. As explained therein, ((
))SRI 18 III.
THE PETITION SHOULD BE DENIED BECAUSE WATERKEEPER STILL HAS NOT PROPOSED AN ADMISSIBLE CONTENTION Waterkeeper proposes one additional contention in its Supplement. As explained below, that contention does not meet all six admissibility criteria in 10 C.F.R. § 2.309(f)(1)(i)-(vi).
Thus, the Board should DENY the Petition in accordance with 10 C.F.R. § 2.309(a)(1).
A.
Contention Admissibility Requirements Under 10 C.F.R. § 2.309(a)(1), a hearing request and petition to intervene may be granted only if the presiding officer determines that the petitioner has proposed at least one admissible contention that meets all six of the threshold admissibility criteria in 10 C.F.R. § 2.309(f)(1).19 14 CPA, Part VII at III (emphasis added).
15 Id., Part VII at III to VII.
16 Id., Part VII at VIII to X.
17 See AIA Rule, 74 Fed. Reg. at ((
19 A proposed Contention must: (i) provide a specific statement of the issue of law or fact to be raised or controverted; (ii) provide a brief explanation of the basis for the contention; (iii) demonstrate that the issue raised is within the scope of the proceeding; (iv) demonstrate that the issue raised is material to the findings the
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These criteria are strict by design.20 A detailed summary of the applicable criteria is provided in LMEs Answer to the Petition,21 and is incorporated-by-reference here. Of particular relevance to the Supplement, that summary explains that a petitioners imprecise reading of a document cannot support a litigable contention,22 and challenges to NRC rules are prohibited as outside the scope of a proceeding because, absent a waiver, no rule or regulation of the Commission... is subject to attack... in any adjudicatory proceeding.23 B.
Contention 5 (AIA) Is Inadmissible Waterkeeper proposes one SUNSI-based contention arguing that ((
))SRI But, contrary to 10 C.F.R. § 2.309(f)(1), this contention is immaterial, unsupported, out-of-scope, and fails to demonstrate a genuine dispute with the CPA. As explained in Subsection III.B.1, below, Contention 5 is fundamentally immaterial and out-of-scope because ((
))SRI simply is not subject to challenge here. And even if it were, Subsection III.B.2 explains that Contention 5 still would be inadmissible because
((
))SRI Finally, Subsection III.B.3 explains that footnote 7 in the Supplement ((
NRC must make to support the action involved in the proceeding; (v) provide a concise statement of the alleged facts or expert opinions, referring to the specific sources and documents that support the petitioners position and on which the petitioner intends to rely; and (vi) provide sufficient information to show that a genuine dispute exists with the applicant on a material issue of law or fact. 10 C.F.R. § 2.309(f)(1).
20 Dominion Nuclear Conn., Inc. (Millstone Nuclear Power Station, Units 2 & 3), CLI-01-24, 54 NRC 349, 358 (2001).
21 LME Ans. to Pet. § IV.A.
22 See, e.g., Interim Storage Partners, LLC (WCS Consol. Interim Storage Facility), CLI-20-14, 92 NRC 463, 477-78 (2020) (a contention based on a misreading of a document cannot supply the requisite support for an admissible contention); Ga. Inst. of Tech. (Ga. Tech Research Reactor, Atlanta, Ga.), LBP-95-6, 41 NRC 281, 300 (1995) (A petitioner's imprecise reading of a reference document cannot serve to generate an issue suitable for litigation.).
23 10 C.F.R. § 2.335(a).
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))SRI does not support the contention because ((
))SRI In sum, Contention 5 is inadmissible for multiple reasons.
1.
Waterkeeper Improperly Challenges ((
))SRI In Contention 5, Waterkeeper contends that ((
))SRI However, this claim is immaterial and beyond the scope of the proceeding and fails to identify a dispute with the CPA on a material issue of law or fact.
As an initial matter, Waterkeeper apparently seeks to challenge ((
))SRI 25 But Waterkeeper seems unaware that ((
))SRI To the extent Waterkeeper believes that Section 3.12 of the PSAR ((
))SRI Waterkeeper simply misreads the CPA. Section 3.12 of the PSAR ((
))SRI Waterkeepers misreading of the application cannot supply the basis for an admissible contention.27 Additionally, Waterkeepers argument alleges ((
))SRI But, as a matter of law, the CPA is not required to ((
))SRI The CPA is required to ((
))SRI provide a description of certain 24 Supplement at 5.
25 Id.
26 AIA Rule, 74 Fed. Reg. at ((
))SRI 27 See ISP, CLI-20-14, 92 at 477-78; Ga. Tech., LBP-95-6, 41 NRC at 300.
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information specified in 10 C.F.R. § 50.150(b).28 Waterkeeper does not acknowledge the correct regulation. It is not specifically cited in Contention 5. It is not quoted in Contention 5. And no part of Contention 5 offers any comparison of PSAR Section 3.12 against the (unacknowledged) requirements in 10 C.F.R. § 50.150(b). Waterkeepers misunderstanding of the regulatory framework cannot supply the basis for an admissible contention.29 And the Board is not empowered to convert Waterkeepers challenge from one alleging ((
))SRI into a different challenge alleging nonsatisfaction of Section 50.150(b).30 Finally, the Commission has clearly stated that ((
))SRI Yet, that is precisely what Waterkeeper offers here. Waterkeeper argues that ((
))SRI By challenging ((
))SRI Waterkeeper proffers a contention that is immaterial, contrary to 10 C.F.R.
§ 2.309(f)(1)(iv), is beyond the scope of this proceeding, contrary to 10 C.F.R. § 2.309(f)(1)(iii),
and fails to raise a genuine dispute with the CPA on a material issue of law or fact, as required by 10 C.F.R. § 2.309(f)(1)(vi).
28 AIA Rule, 74 Fed. Reg. at 28,120.
29 See ISP, CLI-20-14, 92 at 477-78; Ga. Tech., LBP-95-6, 41 NRC at 300.
30 See DTE Elec. Co. (Fermi Nuclear Power Plant, Unit 2), CLI-15-18, 82 NRC 135, 149 (2015) (the Board may not... make arguments for the litigants that were never made by the litigants themselves.).
31 AIA Rule, 74 Fed. Reg. at ((
))SRI 32 Supplement at 4, 5.
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- 2.
Waterkeepers ((
))SRI Arguments Are Legally and Factually Unsupported, Out-of-Scope, and Fail to Raise a Genuine Material Dispute Even assuming arguendo that Waterkeeper is permitted to challenge ((
))SRI (it is not) or that the Board is empowered to amend Contention 5 to allege nonsatisfaction of 10 C.F.R. § 50.150(b) (it is not), the contention still would be inadmissible.
Waterkeepers chief complaint is that ((
))SRI 33 But, contrary to 10 C.F.R. § 2.309(f)(1)(v), Waterkeeper identifies no factual or expert support for its conclusory assertion that ((
))SRI Indeed, not only is this legal theory unsupported, but it also overlooks and contradicts ((
))SRI And to the extent Waterkeeper ((
))SRI Contention 5 also raises an impermissible challenge to the regulations themselves. Thus, even overlooking the fundamental defects identified in Subsection III.B.1, above, Contention 5 still would fail to demonstrate a genuine dispute on a material issue, with references to requisite support, as required by 10 C.F.R. § 2.309(f)(1)(v) and (vi), and still raises out-of-scope issues, contrary to 10 C.F.R. § 2.309(f)(1)(iii)
Waterkeepers overarching claim is that PSAR Section 3.12 ((
))SRI 34 But this criticism does not ((
))SRI at all. In fact, it overlooks a crucial regulatory principle ((
33 Id. at 4-6.
34 Id. at 4.
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))SRI Specifically, the Commission stated that:
((
))SRI This regulatory structure acknowledges ((
))SRI 36 In contrast, ((
))SRI Waterkeeper fails to grapple with the fact that ((
))SRI Simply put, Waterkeeper assumesincorrectlythat ((
))SRI But its misunderstanding of ((
))SRI supplies no basis for an admissible contention.
Waterkeepers arguments fundamentally contradict ((
35 AIA Rule, 74 Fed. Reg. at ((
))SRI (emphasis added).
36 Further, Waterkeeper offers no reason that it was unreasonable for LME to ((
))SRI CONTAINS SECURITY RELATED INFORMATION SUBJECT TO PROTECTIVE ORDER
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))SRI The AIA Rule contemplates that ((
))SRI 37 There is no basis to assert that ((
))SRI And to the extent Waterkeeper argues that ((
))SRI its argument impermissibly challenges NRC regulations and is outside the scope of this proceeding.38 At bottom, Waterkeeper identifies no support for ((
))SRI it seeks to impose here. Waterkeeper cites no case law, no precedent, and no other documents that allegedly support its claim that ((
))SRI Conspicuously, Contention 5 also is not accompanied by any expert declarations. And Waterkeeper disregards the relevant information in ((
))SRI It is Waterkeepers obligation to
[p]rovide a concise statement of the alleged facts or expert opinions which support [its]
position.39 Yet, it has not done so here. Because this contention does not meet the minimum pleading requirements in 10 C.F.R. § 2.309(f)(1)(v) and (vi) and appears to raise issues beyond the scope of this proceeding contrary to 10 C.F.R. § 2.309(f)(1)(iii), it is inadmissible.
37 AIA Rule, 74 Fed. Reg. at ((
))SRI 38 See 10 C.F.R. § 2.335(a) (challenges to NRC rules are prohibited as outside the scope of a proceeding because, absent a waiver, no rule or regulation of the Commission... is subject to attack... in any adjudicatory proceeding.). This prohibition includes claims that the NRCs regulations are not stringent enough. Nuclear Fuel Serv., Inc. (License Amendment Application), CLI-23-3, 98 NRC 33, 49 (2023).
39 See 10 C.F.R. § 2.309(f)(1)(v); See also Tenn. Valley Auth. (Bellefonte Nuclear Power Plant, Units 3 & 4),
LBP-08-16, 68 NRC 361, 384 (2008), revd in part on other grounds, CLI-09-3, 69 NRC 68 (2009).
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- 3.
Waterkeepers Footnote 7 Provides No Basis for a Contention Lastly, buried in a footnote on page 3 of the Supplement, Waterkeeper appears to
((
))SRI Specifically, Waterkeeper points to a recommendation that, for new reactors that generate process heat in addition to electricity, the NRC Staff should evaluate aircraft impacts as part of the external hazards analysis and the siting evaluation.41 Waterkeeper then notes that LME would generate process heat at the LMGS and ((
))SRI 42 But this provides no basis for a contention because ((
))SRI 43 Also, the external hazards analysis and the siting evaluation ((
))SRI and Waterkeeper does not claim or show otherwise. ((
))SRI 44 which Contention 5 does not discuss or dispute. Thus, neither Waterkeepers
((
))SRI identify a genuine dispute on a material issue.
At bottom, Contention 5 is inadmissible for multiple, overlapping reasons and does not satisfy all six admissibility criteria in 10 C.F.R. § 2.309(f)(1). Accordingly, Contention 5 should be rejected as inadmissible.
40 Supplement at 3 n.7.
41 Id. (citing DANU-ISG-2022-01, Interim Staff Guidance; Review of Risk-Informed, Technology-Inclusive Advanced Reactor ApplicationsRoadmap at 43 (Mar. 2024) (ML23297A158)).
42 Id.
43 See, e.g., LME Ans. to Pet. § ((
))SRI 44 See generally, e.g., ((
))SRI
CONTAINS SECURITY RELATED INFORMATION - SUBJECT TO PROTECTIVE ORDER 13 IV.
CONCLUSION As established above, Waterkeeper still has not proposed at least one admissible contention because Contention 5 does not meet the requirements of 10 C.F.R. § 2.309(f)(1).
Because Contentions 1 through 4 are also inadmissible, pursuant to 10 C.F.R. § 2.309(a), the Board should DENY the Petition.
Respectfully submitted, Signed (electronically) by Ryan K. Lighty RYAN K. LIGHTY, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 (202) 739-5274 ryan.lighty@morganlewis.com Executed in Accord with 10 C.F.R. § 2.304(d)
ALEX S. POLONSKY, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 (202) 739-5830 alex.polonsky@morganlewis.com Counsel for Long Mott Energy, LLC Dated in Washington, DC this 19th day of September 2025
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
LONG MOTT ENERGY, LLC (Long Mott Generating Station)
Docket No. 50-614-CP September , 2025 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, a copy of the foregoing UHGDFWHGYHUVLRQRILong Mott Energy, LLCs Answer to San Antonio Bay Estuarine Waterkeepers Hearing Request Supplement was served upon the Electronic Information Exchange (the NRCs E-Filing System) as a Public Submission on the above-captioned docket.
Signed (electronically) by Ryan K. Lighty RYAN K. LIGHTY, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 (202) 739-5274 ryan.lighty@morganlewis.com Counsel for Long Mott Energy, LLC