ML25258A239
| ML25258A239 | |
| Person / Time | |
|---|---|
| Site: | Abilene Christian University |
| Issue date: | 09/15/2025 |
| From: | Robison J Natura Resources |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25258A234 | List: |
| References | |
| Download: ML25258A239 (1) | |
Text
400 PINE ST SUITE 750 ABILENE, TX 79601 NATURARESOURCES.COM Page 1 of 2 Request for Withholding from Public Disclosure and Affidavit in Accordance with 10 CFR 2.390(a)(4)
Natura Resources (Natura) is funding the construction of the Abilene Christian University (ACU)
Molten Salt Research Reactor (MSRR), and as part of the funding effort, is licensing to ACU the design of Naturas MSR-1, a 1 MWth molten salt reactor (MSR). In addition, Natura has entered into sponsored research agreements with ACU and three other universities (Other Universities) to assist in the development of the MSR system and the construction of the MSRR whereby Natura owns exclusive rights to the intellectual property developed under those sponsored research agreements. In addition to the sponsored research agreements, the contracting agreements led by Natura protect Natura rights to the intellectual property developed under the contracts. Under these agreements, the intellectual property developed is confidential and considered trade secrets of Natura unless Natura has opted to publicly disclose and/or file a patent application on the technology. As owner of these exclusive proprietary and confidential rights, Natura is executing this affidavit to support the protection of those rights during the NRC review of licensing-related documents submitted by ACU for the MSRR.
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. The information sought to be withheld, in its entirety, with this request is contained in, which accompanies this Affidavit.
- 3. 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.
- 4. The request for withholding is based upon the following:
- a. The information sought to be withheld is owned and has been held in confidence by ACU, the Other Universities, contractors, and Natura as confidential and proprietary, trade secret information.
- b. The information is of a type that is customarily held in confidence by ACU, the Other Universities, contractors, and 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.
400 PINE ST SUITE 750 ABILENE, TX 79601 NATURARESOURCES.COM Page 2 of 2
- 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. The information consists of supporting data relative to a process, component, structure, tool, method, etc., and the application of the data 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, shipment, installation, assurance of quality, or licensing of a similar product.
- 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 process for the design of the molten salt reactor.
Natura has expended a considerable sum of money to fund significant research and evaluation to develop a basis for the design information, including that with contractors, ACU, and the Other Universities. 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 September 15, 2025.
Jordan Robison Vice President of Engineering and Program Management Natura Resources Jordan Robison (Sep 15, 2025 14:35:43 CDT)
Jordan Robison