ML26022A311
| ML26022A311 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 01/22/2026 |
| 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 57581, ASLBP 25-991-01-CP-BD01, 50-614-CP | |
| Download: ML26022A311 (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)
§
§
§
§
§
§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 January 22, 2026 SAN ANTONIO BAY ESTUARINE WATERKEEPERS MOTION FOR ONE-DAY EXTENSION OF TIME TO FILE REPLY PLEADING San Antonio Bay Estuarine Waterkeeper (Waterkeeper or Petitioner) hereby requests a one-day extension of Waterkeepers deadline for the 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 original deadline for the filing of Waterkeepers Reply Pleading was January 21, 2026, and Waterkeepers requested extension would make the new deadline January 22, 2026.
The August 28, 2025 Initial Prehearing Order states that a motion for extension of time shall be submitted at least three business days before the due date for the pleading for which an extension is sought.1 It further states, A motion for extension of time must (1) indicate whether the request is opposed or supported by the other participants to the proceeding; and (2) demonstrate appropriate cause that supports permitting the extension.2 1 Memorandum and Order (Initial Prehearing Order) (Aug. 28, 2025), at 5.
2 Id.
2 This Motion is opposed by both Long Mott Energy, LLC (LME) and NRC Staff.
Good cause exists for Waterkeepers filing of this motion less than three business days before the original deadline of January 21, 2026, in accordance with the Initial Prehearing Order. Just before the filing deadline, Counsel for Petitioner, awaiting a document from Petitioners expert, notified counsel for the NRC Staff and LME by email that they were experiencing technical difficulties that delayed his finalizing the document and transmitting it to her for filing. Counsel for Petitioner advised that she intended to seek a one-day extension of time to submit Waterkeepers Reply, though she anticipated needing less time to resolve the issues. By email, today, Counsel for NRC Staff and LME indicated that they both oppose this request.
Waterkeepers counsel had another deadline (to submit a hearing request, with accompanying expert reports) on Tuesday, January 20, 2026, in the matter of: Application by Fermi Equipment Holdco, LLC for Proposed Air Quality Permit Nos. 181009, PSDTX1670, and GHGPSDTX254, pending before the Texas Commission on Environmental Quality. This limited the amount of time available for Counsel to address any technical difficulties ahead of the January 21, 2026 filing deadline in this matter.
Neither NRC Staff nor LME will be prejudiced by this requested one-day extension.
The requested deadline extension is for a Reply to Staffs and LMEs Answers to Waterkeepers Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR. This Reply pleading does not seek to add or amend a contention, but rather, provides responsive arguments in support of the Motion that Waterkeeper timely filed. A one-day extension for filing this Reply will not affect Staff or
3 LME because there is no applicable deadline for Staff or LME to submit further pleadings in response to Waterkeepers Reply. LME and the Staff already filed their Responses a full 14 days after Waterkeepers timely filed Motion.
Waterkeeper respectfully requests the Board grant a one-day extension of Waterkeepers deadline for the Reply in Support of its Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR.
Date: January 22, 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)
§
§
§
§
§
§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 January 22, 2026 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on January 22, 2026, copies of the foregoing San Antonio Bay Estuarine Waterkeepers Motion for One-Day Extension of Time to File 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