ML25346A260
| ML25346A260 | |
| Person / Time | |
|---|---|
| Site: | 05000614, 99902117 |
| Issue date: | 12/12/2025 |
| From: | Vaughn S X-Energy |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25346A256 | List: |
| References | |
| 2025-PLM-NRC-016 | |
| Download: ML25346A260 (0) | |
Text
X Energy, LLC 801 Thompson Avenue Rockville, MD 20852
+1 301.358.5600 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 II entitled Preliminary Safety Analysis Report, of the Long Mott Energy, LLC (LME) construction permit application (CPA) for Long Mott Generating Station (LMGS), which is provided as Enclosure 4a to LME Letter No. 2025-PLM-NRC-016 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.
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.
X Energy, LLC 801 Thompson Avenue Rockville, MD 20852
+1 301.358.5600 www.x-energy.com Page 2 of 2 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 12th day of December 2025.
Sincerely, Stephen Vaughn Director, Licensing X Energy, LLC ephen Vaughn