ML25216A265
| ML25216A265 | |
| Person / Time | |
|---|---|
| Site: | 05000614, 99902117 |
| Issue date: | 08/04/2025 |
| From: | Stones E Long Mott Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25216A264 | List: |
| References | |
| 2025-PLM-NRC-007 | |
| Download: ML25216A265 (1) | |
Text
Long Mott Energy August 4, 2025 2025-PLM-NRC-007 Project No. 99902117 Docket No. 50-614-CP ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Submial of Long Mo Energy, LLC, Construcon Permit Applicaon, Part VII, Security-Related Informaon to be Withheld per 10 CFR 2.390(d)(1), Revision 0 with Updated Proprietary Markings; Withdrawal of Administrave Update Submied July 17, 2025
References:
1)
Long Mo Energy, LLC, Submial of the Long Mo Energy, LLC, Construcon Permit Applicaon for Long Mo Generang Staon, 2025-PLM-NRC-003, March 31, 2025 2)
X Energy, LLC, X Energy, LLC Response to NRC Leer Granng Access to Requestors of Redacted Informaon in the Long Mo Generang Staon Construcon Permit Applicaon, 2025-PLM-NRC-005, July 10, 2025 3)
Long Mo Energy, LLC, Submial of Long Mo Energy, LLC, Construcon Permit Applicaon, Part VII, Security-Related Informaon to be Withheld per 10 CFR 2.390(d)(1), Revision 0 with Proprietary Markings, 2025-PLM-NRC-006, July 17, 2025 This leer submits to the Nuclear Regulatory Commission (NRC) an administrave update to Part VII, Security-Related Informaon to be Withheld per 10 CFR 2.390(d)(1), of the Long Mo Energy, LLC (LME) Construcon Permit Applicaon (CPA) that was submied for Long Mo Generang Staon (LMGS) on March 31, 2025 (Reference 1). This update to CPA Part VII, provided as Enclosure 1 to this leer, pertains only to proprietary markings added to specic porons of CPA Part VII to reect the dual-sensive and proprietary nature of the informaon as further explained below. Otherwise, the content of CPA Part VII is unchanged and is idencal to the CPA Part VII, Revision 0, that was submied as to Reference 1. The enclosed updated CPA Part VII, Revision 0, with both SRI and proprietary markings, supersedes in its enrety the CPA Part VII, Revision 0, previously submied (with SRI markings only) as Enclosure 7 to Reference 1.
Further to the above, Part VII of the LMGS CPA submied March 31, 2025, contains informaon that is designated and appropriately marked as security-related sensive unclassied non-safeguards informaon (SUNSI), referred to as security-related informaon (SRI), and as such was requested in Reference 1 to be withheld under 10 CFR 2.390(d)(1). X Energy, LLC (X-energy) recently conrmed (Reference 2) that specic porons of CPA Part VII are integral to X-energys proprietary design methodology and trade secrets, and as such represent both SRI (as originally marked) and proprietary informaon owned by X-energy. Accordingly, proprietary markings are added as appropriate to CPA Part VII, as shown in Enclosure 1 to this leer. transmied herewith contains sensive, unclassied security-related informaon.
When separated from the sensive informaon, this transmial leer is decontrolled.
2025-PLM-NRC-007 August 4, 2025 Page 2 of 3 Please note that a similar administrave update of CPA Part VII, Revision 0, with added proprietary markings was recently submied as Enclosure 1 to LME leer dated July 17, 2025 (Reference 3), together with LMEs request for the informaon marked as proprietary to be withheld from public disclosure under 10 CFR 2.390(a)(4) and 10 CFR 2.390(b). In response to NRC feedback on the July 17, 2025, submial, the proprietary markings added in CPA Part VII have been further rened to clarify and disnguish between sensive porons and porons having both a dual-sensive and proprietary nature.
The claried proprietary markings version of LMGS CPA Part VII provided as Enclosure 1 to this leer is intended to supersede in its enrety the earlier proprietary markings version submied as Enclosure 1 to Reference 3. As such, LME requests that the earlier version (Reference 3) be withdrawn from Commission consideraon as provided for in 10 CFR 2.390(c)(3).
LME further requests the informaon in Enclosure 1 marked as proprietary be withheld from public disclosure under 10 CFR 2.390(a)(4) and in accordance with the requirements of 10 CFR 2.390(b). The X-energy adavit accompanying this leer as Aachment 2 supports this request. Also provided as Aachment 1 to this leer is a conforming update to (and as such, supersedes) the informaon previously provided as Aachment 1 to Reference 1 and updated in Aachment 1 to Reference 3, that describes the nature and locaon of CPA informaon requested to be withheld. LMEs request in its original LMGS CPA submial (Reference 1) for the informaon marked as SRI to be withheld from public disclosure under 10 CFR 2.390(d)(1) is unaected by this submial.
There are no regulatory commitments idened in this leer or its aachments and enclosure.
Please address quesons related to this submial to the following points of contact:
Name:
Mark Feltner
Title:
Technology Principal, Nuclear Power Address: The Dow Chemical Company 530 Gaither Road Rockville, MD 20850 Email:
mfeltner@dow.com Phone:
(225) 485-3285 Name:
Stephen Vaughn
Title:
Director, Licensing Address: X Energy, LLC 530 Gaither Road Rockville, MD 20850 Email:
svaughn@x-energy.com Phone:
(360) 471-8591 Sincerely, Edward Stones President Long Mo Energy, LLC
2025-PLM-NRC-007 August 4, 2025 Page 3 of 3 Aachments:
Aachment 1 Informaon Requested to be Withheld from Public Disclosure (supersedes Aachment 1 to LME Leer No. 2025-PLM-NRC-003 and Aachment 1 to LME Leer No. 2025-PLM-NRC-006)
Aachment 2 X Energy, LLC Adavit Supporng Request for Withholding from Public Disclosure per 10 CFR 2.390(a)(4)
Enclosures:
Part VII - Security-Related Informaon to be Withheld per 10 CFR 2.390(d)(1)
(non-public; proprietary and SRI) (supersedes Enclosure 7 to LME Leer No. 2025-PLM-NRC-003 and Enclosure 1 to LME Leer No. 2025-PLM-NRC-006) cc:
Dow:
Kreshka Young Charles OConnor Mark Feltner Wayne Blaylock Edward Stones Evan Blankenau X Energy, LLC:
David Bannister Harlan Bowers Steve Miller Rob Taylor Steve Vaughn Jessica Maddocks U.S. Department of Energy:
Je Ciocco David Yarwood U.S. Nuclear Regulatory Commission:
^WŽ Adrian Muniz Ondra Dukes Denise McGovern Richard Rivera John Monninger, NRC Region IV
Long Mott Energy to Long Mott Energy, LLC (LME), Letter No. 2025-PLM-NRC-007 (Supersedes Attachment 1 to LME Letter No. 2025-PLM-NRC-003 and Attachment 1 to LME Letter No. 2025-PLM-NRC-006)
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Long Mott Energy to Long Mott Energy, LLC, Letter No. 2025-PLM-NRC-007 X Energy, LLC, Affidavit Supporting Request for Withholding from Public Disclosure per 10 CFR 2.390(a)(4)
X Energy, LLC 530 Gaither Road, Suite 700 Rockville, MD 20850 (301) 358-5600 www.x-energy.com Page 1 of 2 X Energy, LLC Affidavit Supporting Request for Withholding from Public Disclosure per 10 CFR 2.390(a)(4)
I, Stephen Vaughn, Director, Licensing, of X Energy, LLC (X-energy) do hereby affirm and state:
- 1. I am authorized to execute this Affidavit on behalf of X-energy. I am further authorized to review information submitted to or discussed with the U.S. Nuclear Regulatory Commission (NRC) and apply for the withholding of information from public disclosure on behalf of X-energy.
- 2. The information sought to be withheld, in its entirety, is contained in Part VII, Security-Related Information to be Withheld per 10 CFR 2.390(d)(1), Revision 0 with proprietary markings, of the Long Mott Energy, LLC (LME) construction permit application (CPA) for Long Mott Generating Station (LMGS).
The LMGS CPA Part VII with proprietary markings is provided as Enclosure 1 to LME Letter No. 2025-PLM-NRC-007 to which this affidavit is Attachment 2. The information considered by X-energy to be confidential or proprietary is identified in the document within double brackets "(( ))" accompanied by a superscripted XE.
- 3. The basis for proposing that the information be withheld is that X-energy treats the information as a trade secret, privileged, or as confidential commercial or financial information pursuant to the exemption from public disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC 552(b)(4) and NRC regulations 10 CFR 2.390(a)(4) and 10 CFR 9.17(a)(4).
- 4. I am knowledgeable of the criteria and procedures used by X-energy in designating information as a trade secret, privileged, or as confidential commercial or financial information that would be protected from public disclosure under 10 CFR 2.390(a)(4).
- 5. Pursuant to 10 CFR 2.390(b)(4), the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.
a.
The information sought to be withheld from public disclosure is owned by X-energy. This information was prepared with the explicit understanding that the information itself would be treated as proprietary and confidential and has been held in confidence by X-energy.
b.
The information sought to be withheld is of a type that is customarily held in confidence by X-energy, and there is a rational basis for doing so. The information X-energy is requesting to be withheld from public disclosure includes technical information related to the design of the X-energy Xe-100 high-temperature, gas-cooled, pebble bed advanced reactor design that directly impacts X-energys business development and commercialization efforts. Disclosures outside X-energy of this information are limited to regulatory bodies, customers and potential customers, and their agents, suppliers, licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or contractual agreements to maintain confidentiality.
X Energy, LLC 530 Gaither Road, Suite 700 Rockville, MD 20850 (301) 358-5600 www.x-energy.com Page 2 of 2 c.
The information sought to be withheld is transmitted to the NRC in confidence, and under the provisions of 10 CFR 2.390 it is to be received in confidence by the NRC.
d.
The information sought to be withheld is not available in public sources.
e.
Although not required pursuant to Food Marketing Institute v. Argus Leader Media, 139 S. Ct. 2356 (2019), X-energy asserts that public disclosure of this non-public information is likely to cause substantial harm to the competitive position of X-energy, 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.
I declare under the penalty of perjury that the foregoing is true and correct.
Executed on this 4th day of August 2025.
Sincerely, Stephen Vaughn Director, Licensing X Energy, LLC ephen Vaughn