ML24030A014
| ML24030A014 | |
| Person / Time | |
|---|---|
| Site: | 99902088, Abilene Christian University |
| Issue date: | 01/29/2024 |
| From: | Robison J Natura Resources |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML24030A013 | List: |
| References | |
| Download: ML24030A014 (1) | |
Text
Natura Resources 400 Pine Street, Suite 750 Abilene, TX 79601 naturaresources.org/
January 29, 2023 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 205550001
Subject:
Natura Resources Plan for Regulatory Engagement I am pleased to introduce Natura Resources, LLC to the Nuclear Regulatory Commission staff. As described further in the enclosed Plan for Regulatory Engagement, Natura is supporting Abilene Christian University in the development of the Molten Salt Research Reactor. Natura was introduced to Chair Hanson and Commissioner Wright when they visited Abilene Christian University. Natura is scheduling drop-in meetings to discuss our plans with Commissioners Caputo and Crowell in the near future.
The enclosed Plan for Regulatory Engagement briefly describes Naturas background, conceptual design for a molten salt reactor, licensing strategy, and plans for pre-application activities. Natura will update this Plan as the design advances and the schedule for pre-application activities becomes more defined.
The Plan contains information that is proprietary and confidential to Natura. Natura requests that Enclosure 1 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. An affidavit supporting the withholding request is provided in Enclosure 2.
If you have questions, please contact me at jordan.robison@naturaresources.org.
- Regards, Jordan Robison Vice President of Engineering and Program Management
Enclosures:
- 1. Proprietary Plan for Regulatory Engagement with the Nuclear Regulatory Commission
- 2. Request for Withholding from Public Disclosure and Affidavit in Accordance with 10 CFR 2.390(a)(4)
Cc:
William Jessup, Chief, NRR Advanced Reactor Licensing Branch 1 Michael Wentzel, Chief, NRR Advanced Reactor Licensing Branch 2
Request for Withholding from Public Disclosure and Affidavit in Accordance with 10 CFR 2.390(a)(4)
I, Jordan Robison, state:
- 1. I am the Vice President of Engineering and Program Management for Natura Resources. I have been specifically delegated the function of reviewing the information to be withheld and I am authorized to apply for the withholding of the information on behalf of Natura.
- 2. I request withholding of the identified information, and execute this affidavit in support of the request, pursuant to the provisions of 10 CFR 2.390(b)(1).
- 3. The information sought to be withheld, in its entirety, with this request is contained in Enclosure 1, which accompanies this Affidavit.
- 4. Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
- a. The information sought to be withheld has been held in confidence by Natura as confidential commercial information.
- b. The information is of a type that is customarily held in confidence by Natura based on the rationale described in this affidavit.
- c. The information is being transmitted to and, pursuant to 10 CFR 2.390, received by the NRC in confidence.
- d. No public disclosure of the information has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or contractual agreements that provide for maintenance of the information in confidence.
- e. The information requested to be withheld reveals specific distinguishing design aspects and commercial plans. The information consists of conceptual designs and business plans, and the application of the design concepts and business strategy secures a competitive economic advantage as described in paragraph 5.
- f. Use by a competitor of the information requested to be withheld would reduce the competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, or licensing of a similar product. This information is the result of considerable expense by Natura and has great value because it will help Natura to provide products and services to markets not currently served by the company.
- 5. Public disclosure of the information sought to be withheld is likely to cause substantial harm to Natura's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying information reveals distinguishing aspects about Naturas proprietary molten salt reactor design and business plans.
Natura has expended a considerable sum of money to fund significant research and evaluation to develop a basis for the design information. The precise financial value of the information is difficult to quantify, but it is a key element of the design basis for a Natura proprietary molten salt reactor design and, therefore, has substantial value to Natura.
If the information were disclosed to the public, Natura's competitors would have access to the information without purchasing or entering into a license for the right to use it or having been required to undertake a similar expenditure of resources. Such disclosure would constitute a misappropriation of Natura's intellectual property and would deprive Natura of the opportunity to exercise its competitive advantage to seek an adequate return on its investment.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on January 29, 2024.
Jordan Robison Vice President of Engineering and Program Management Natura Resources