ML25353A616
| ML25353A616 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 12/19/2025 |
| From: | Perales M Long Mott Energy, NRC/OGC, Perales, Allmon & Ice, P.C., San Antonio Bay Estuarine Waterkeeper |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57564, ASLBP 25-991-01-CP-BD01, 50-614-CP | |
| Download: ML25353A616 (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 19, 2025 JOINT MOTION TO CORRECT THE TRANSCRIPT OF THE PREHEARING CONFERENCE HELD ON DECEMBER 8, 2025 In accordance with 10 C.F.R. §§ 2.323(a) and 2.327(d), San Antonio Bay Estuarine Waterkeeper, Long Mott Energy, LLC, and the NRC Staff jointly submit proposed corrections to the transcript of the prehearing conference held in the above-captioned matter before the Atomic Safety and Licensing Board on December 8, 2025.1 The joint transcript corrections are identified in Attachment 1. The parties have consulted in accordance with 10 C.F.R. § 2.323(b), and each party agrees to the proposed transcript corrections contained in Attachment 1. The parties respectfully request that the transcript be revised to incorporate these corrections.
Respectfully submitted, Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com PERALES, ALLMON & ICE, P.C.
1 On December 9, 2025, the Law Clerk for the Atomic Safety and Licensing Board contacted the parties by email and provided that they may submit a joint motion to correct errors in the transcript within four business days of the date it was received. The parties received the transcript on December 15, 2025. As provided by the Atomic Safety and Licensing Board, this motion is limited to addressing actual errors in transcription, rather than attempting to be more eloquent or correcting misstatements.
2 1206 San Antonio St.
Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)
Counsel for San Antonio Bay Estuarine Waterkeeper
3 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 19, 2025 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on December 19, 2025, copies of the foregoing Joint Motion to Correct the Transcript of the Prehearing Conference Held on December 8, 2025 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
ATTACHMENT 1
ATTACHMENT 1 Parties Joint Proposed Changes/Corrections to Transcript of Oral Argument Held on December 8, 2025 Proposed Corrections by San Antonio Bay Estuarine Waterkeeper Page Line As Written Should Be 21 19 environment environmental 31 22 there is theres 32 9
is as 32 20 B
D 32 23 aesthetic interest aesthetic interests 38 5
put pled 38 16 instead and threat 39 9
TBAs TVAs 40 1
steel sealed 41 7
Applicant Applicants 42 4
recs experts 46 23 eliminated eliminate it 83 10 LME LMEs 144 16 at of 187 21
. Because because 212 9
with in 234 4
declarance declarants 237 9
merit merits Proposed Corrections by NRC Staff Page Line As Written Should Be 26 9
Conditions Contentions 27 4
beyond a 100 meters beyond 100 meters 27 13 presumption, specifically to presumption specifically for 28 6
contention the contention 30 1
argument agreement 30 11 answers answer 53 9
Christopher Kristopher 74 18 LBP-16.5 LBP-16-5 74 19 LB 20-08 LBP-20-08 76 6
as been has been 243 10 demonstrated a representational demonstrated representational
2 244 18 LBP-17.8 LBP-17-8 245 2
5034(a)(8) 50.34(a)(8)
Proposed Corrections by Long Mott Energy, LLC Page Line As Written Should Be 49 14 plead pled 52 13 education educated 56 10 if the if 58 23 commission Commission 62 21 apply here apply it here 66 20 requests that self request, itself, 67 24 If its Its 69 22 allocations allegations 71 25 parameter perimeter 127 19 of with 168 25 was is 171 16 protections projections 173 10 MR. LIGHTY MR. STEPHENS 181 10 are arent 185 23 question discretion 216 25 You You've 240 3
The That 240 7
criteria and the criteria in the 240 10 5034 Bravo 50.34(b) 242 17 prop prong