ML25349B339
| ML25349B339 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 12/15/2025 |
| From: | Perales M Perales, Allmon & Ice, P.C., San Antonio Bay Estuarine Waterkeeper |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57558, ASLBP 25-991-01-CP-BD01, 50-614-CP | |
| Download: ML25349B339 (0) | |
Text
1 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)
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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 December 15, 2025 SAN ANTONIO BAY ESTUARINE WATERKEEPERS NOTIFICATION REGARDING LMEs SUPPLEMENTAL INFORMATION San Antonio Bay Estuarine Waterkeeper (Waterkeeper or Petitioner) submits this Notification to advise the Atomic Safety and Licensing Board (the Board) and the participants to this proceeding of Waterkeepers position regarding NRC Staffs December 3, 2025 Notification Regarding Supplemental Information.
I.
Background
Relevant to this Notification, LME submitted three Supplements to its CPA:
- Confirmatory Information Regarding Environmental Report (Supplement 2 to the ER), Cover Letter dated October 17, 2025 (added to ADAMS October 27); and
2 On December 3, 2025, NRC Staff submitted a Notification Regarding Supplemental Information, indicating that, in Staffs estimation, the three supplements (listed above) mooted portions of Contentions 1 and 4 in Waterkeepers Petition to Intervene and Request for Hearing. That is, in their Answer to Waterkeepers Petition, the NRC Staff characterized parts of Contentions 1 and 4 as contentions of omission, which, in Staffs estimation, were admissible. By their December 3, 2025 Notification, NRC Staff indicated that, because LME submitted supplements that included the omitted information, Staffs position had changed, and Staff now considered those portions of Contentions 1 and 4 as moot.
During the Prehearing Conference convened by the Board on December 8, 2025, Chair Wolfe inquired about Waterkeepers position regarding the issues identified in Staffs Notification, and more specifically, whether Waterkeeper agreed that the issues were now moot. Waterkeepers counsel committed to providing a statement of Waterkeepers position regarding Staffs December 3 Notification by todaya week after the December 8, 2025 Prehearing Conference.
II.
Waterkeepers Position By Waterkeepers Motion to Amend its Contention 1 Based on PSAR Supplement 1, dated December 5, 2025, Waterkeeper has explained its position regarding this supplement to LMEs PSAR. That is, Waterkeeper maintains that the supplemental information has not mooted any portion of Waterkeepers Contention 1.
By Waterkeepers Motion to Amend Contention 4 Based on ER Supplement 2, dated December 12, 2025, Waterkeeper has explained its position regarding the October
3 17, 2025 supplemental submittal, which addressed, in part, continued storage of spent nuclear fuel. That is, Waterkeeper maintains that the supplemental information has not mooted that portion of Waterkeepers Contention 4 that addressed continued storage of spent nuclear fuel.
With regard to LMEs Supplement 2 to the PSAR, dated November 20, 2025, Waterkeeper is continuing to evaluate that supplemental submission in relation to its Contention 4. Based on a preliminary evaluation, Waterkeeper anticipates submitting a Motion to Amend Contention 4 based on PSAR Supplement 2, which will include an explanation about why PSAR Supplement 2 does not moot Contention 4. Such a Motion is due on December 31, 2025, which is 30 days after PSAR Supplement 2 was made publicly available. Waterkeeper will submit any Motion to Amend its Contention 4 based on that Supplement on or before that deadline.
Respectfully submitted, Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com PERALES, ALLMON & ICE, P.C.
1206 San Antonio St.
Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)
Counsel for San Antonio Bay Estuarine Waterkeeper
4 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)
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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 December 15, 2025 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on December 15, 2025, copies of the foregoing San Antonio Bay Estuarine Waterkeepers Notification Regarding LMEs Supplemental Information were served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned docket.
Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com PERALES, ALLMON & ICE, P.C.
1206 San Antonio St.
Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)
Counsel for San Antonio Bay Estuarine Waterkeeper