ML26015A530
| ML26015A530 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 01/15/2026 |
| From: | Hanson S, Perales M Perales, Allmon & Ice, P.C., San Antonio Bay Estuarine Waterkeeper |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57577, EPID 25-991-01-CP-BD01, 50-614-CP | |
| Download: ML26015A530 (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 January 15, 2026 SAN ANTONIO BAY ESTUARINE WATERKEEPERS MOTION FOR LEAVE TO EXCEED THE PAGE LIMIT FOR REPLY PLEADING In accordance with the Atomic Safety and Licensing Boards (Board) August 28, 2025 Memorandum and Order (Initial Prehearing Order), San Antonio Bay Estuarine Waterkeeper (Waterkeeper or Petitioner) hereby requests that the Board extend the page limit by three pages for Waterkeepers Reply in Support of its December 31, 2025 Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR.
The Initial Prehearing Order states, Absent preapproval by the Board or some other Board directive, any motion filed after the date of this memorandum and order and any related responsive pleadings shall not exceed ten pages in length (including the signature page, but excluding the certificate of service and any attachments/enclosures).1 It further provides that any motion for leave to exceed this limit must be submitted at least three business days prior to the submittal and that it must (1) indicate (as is the case with any 1 Memorandum and Order (Initial Prehearing Order) (Aug. 28, 2025), at 3.
2 motion) whether the relief requested is opposed or supported by the other participants to the proceeding; (2) provide a good faith estimate of the number of additional pages that will be filed; and (3) demonstrate good cause for being permitted to exceed the page limitation.2 As required by the Initial Prehearing Order, this request is being filed more than three business days prior to the submittal date of January 21, 2026. Waterkeeper estimates that it will need three additional pages. Neither the NRC Staff (Staff) nor Long Mott Energy, LLC (LME or Applicant) opposes this request.
Additionally, Waterkeeper has good cause for seeking to exceed the page limit. In its December 31, 2025 Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR, Waterkeeper moved to amend its Contention 4 based on Supplements 2, 3, and Enclosure 6 to Supplement 4 to the PSAR (Supplements).3 It additionally moved to add a new contention based on the Supplements, addressing LMEs analysis of PMP and PMF on streams and rivers,4 LMEs analysis of potential dam failures,5 and LMEs flood protection analysis.6 In their January 14, 2026 Answers to Waterkeepers Motion, LME and the Staff oppose Waterkeepers motion to amend its Contention 4 and to add a new contention, and they present a number of arguments in support of their respective positions.
2 Id. at 3-4.
3 Waterkeeper Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR (Dec. 31, 2025), at 9 (explaining that the Supplements fail to remedy the PSARs deficiency for failing to consider the effects of climate change in its analysis).
4 Id. at 4-6.
5 Id. at 6-8.
6 Id. at 8-9.
3 Waterkeepers Reply is intended to address two responsive pleadings by two different parties, presenting distinct arguments regarding two contentions based on several supplements to LMEs application. For brevity and judicial efficiency, Waterkeeper seeks to address both responses in a single Reply, but to effectively do so, Waterkeeper estimates it will need three additional pages. Waterkeeper respectfully requests the Boards approval to exceed this page limit by three pages, for a total of thirteen pages.
Date: January 15, 2026 Respectfully submitted, Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com Sidra Hanson Texas Bar No. 24149049 sidra@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 January 15, 2026 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on January 15, 2026, copies of the foregoing San Antonio Bay Estuarine Waterkeepers Motion for Leave to Exceed the Page Limit for Reply Pleading 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 Sidra Hanson Texas Bar No. 24149049 sidra@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