ML21342A241
| ML21342A241 | |
| Person / Time | |
|---|---|
| Site: | 99902069, 07007034 |
| Issue date: | 12/08/2021 |
| From: | Hastings P Kairos Power |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21342A239 | List: |
| References | |
| KP-NRC-2112-001 | |
| Download: ML21342A241 (4) | |
Text
KP -NRC -2 1 12 -001
December 8, 2021 Docket Number: 7007034
US Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 -0001
Subject:
Kairos Power LLC Presentation Materials for the December 14, 2021 Pre -S ubmittal Meeting on the Kairos Power Atlas Fuel Fabrication Facility Application
References:
Letter, Kairos Power LLC to Document Control Desk, Intent to Submit Application for a Fuel Fabrication Facility, October 26, 202 1, (ML 21300A406 )
This letter transmits presentation materials for the subject meeting between Kairos Power and the Nuclear Regulatory Commission (NRC) staff to be held on December 14, 2021. The purpose of this meeting is to discuss pre -application plans for the Kairos Power Atlas F uel Fabrication Facility license application identified in the referenced letter.
Some portions of the presentation materials are considered proprietary, and Kai ros Power requests they be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. Enclosure 1 provides the proprietary slides to be used during the closed session of the subject meeting and E nclosure 2 provides the slides to be used during the public session of the meeting. A n affidavit supporting the withholding request is provided in Enclosure 3.
If you have any questions or need any additional information, please contact James Tomkins at tomkin s@kairospower.com or (805 )-2 1 5 -6129, or Darrell Gardner at gardner @kairospower.com or (704 )-769 -1226.
Sincerely,
Peter Hastings, PE
Vice President, Regulatory Affairs and Quality
Kairos Power LLC www.kairospower.com 707 W Tower Ave, Suite A 5201 Hawking Dr SE, Unit A 2115 Rexford Rd, Suite 325 Alameda, CA 94501 Albuquerque, NM 87106 Charlotte, NC 282 11
KP -NRC -2 1 12 -001 Page 2
Enclosures:
- 1) Closed Session Presentation Materials for the Pre -Submittal Meeting on the Kairos Power Atlas Fuel Fabrication Facility Application (Proprietary )
- 2) Public Session Presentation Materials for the Pre -Submittal Meeting on the Kairos Power Atlas Fuel Fabrication Facility Application
- 3) Affidavit Supporting Request for Withholding from Public Disclosure (10 CFR 2.390)
xc (w/enclosure):
Jason Piotter, Project Manager, NMSS, Fuel Facilit ies Licensing B ranch Jacob Zimmerman, Branch Chief, NMSS, Fuel Facilities Licensing Branch Benjamin Beasley, Project Manager, NRR, Advanced Reactor and Licensing Branch
KP -NRC -2 1 12 -001
Enclosure 3
Kairos Power LLC Affidavit and Request for Withholding from Public Disclosure (10 CFR 2.390)
I, Darrell Gardner, hereby state:
- 1. I am Senior Director, Licensing, at Kairos Power LLC (Kairos), and as such I have been authorized by Kairos to review information sought to be withheld from public disclosure in connection with the development, testing, licensing, and deployment of the Kairos reactor and its associated structures, systems, and components, and to apply for its withholding from public disclosure on behalf of Kairos.
- 2. The information sought to be withheld, in its entirety, is contained in Kairos Enclosure 1 to this letter.
- 3. I am m aking this request for withholding, and executing this affidavit in support thereof, pursuant to the provisions of 10 CFR 2.390(b)(1).
- 4. I have personal knowledge of the criteria and procedures utilized by Kairos in designating information as a trade secret, privileged, or as confidential commercial or financial information.
Some examples of information Kairos considers proprietary and eligible for withholding under
§2.390(a)(4) include:
- a. Information which discloses process, method, or apparatus, including sup porting data and analyses, where prevention of its use by Kairos competitors without license or contract from Kairos constitutes a competitive economic advantage over other companies in the industry;
- b. Information, which if used by a competitor, would reduce his expenditure of resources or improve his competitive position in design, manufacture, shipment, installation, assurance of quality;
- c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of K airos, its customers, its partners, or its suppliers;
- d. Information which reveals aspects of past, present, or future Kairos or customer funded development plans or programs, of potential commercial value to Kairos;
- e. Information which discloses patentable su bject matter for which it may be desirable to obtain patent protection; and/or
- f. Information obtained through Kairos actions which could reveal additional insights into reactor system development, testing, qualification processes, and/or regulatory proceedin gs, and which are not otherwise readily obtainable by a competitor.
- 5. Kairos information contained in Enclosure 1 to this letter contains Kairos Powers detailed schedules for licensing and development of a fuel fabrication facility. These details could pro vide a competitor with a commercial advantage if the information were to be revealed publicly.
KP -NRC -2 1 12 -001
- 6. Pursuant to the provisions of §2.390(b)(4), the following is furnished for consideration by the Commission in determining whether the information sought to be wi thheld from public disclosure should be withheld:
- a. The information sought to be withheld from public disclosure is owned and has been held in confidence by Kairos.
- b. The information is of a type customarily held in confidence by Kairos and not customarily dis closed to the public. Kairos has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. Th e application of that system and the substance of that system constitute Kairos policy and provide the rational basis required.
- c. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR 2.390, it is to be rece ived in confidence by the Commission.
- d. This information is not readily available in public sources.
- e. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Kairos, because it would enhance the ability of competitors to provide similar products and services by reducing their expenditure of resources using similar project methods, equipment, testing approach, contractors, or licensing approaches. This information is the result of considerable exp ense to Kairos and has great value in that it will assist Kairos in providing products and services to new, expanding markets not currently served by the company.
- f. The information could reveal or could be used to infer price information, cost information, b udget levels, or commercial strategies of Kairos.
- g. Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary inf ormation, any one component may be the key to the entire puzzle, thereby depriving Kairos of a competitive advantage.
- h. Unrestricted disclosure would jeopardize the position of Kairos in the world market, and thereby give a market advantage to the competitio n in those countries.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: December 8, 2021
Darrell Gardner Senior Director, Licensing