ML061030324

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Structural Integrity Associates, Inc. - Request for Withholding Information from Public Disclosure for San Onofre, Unit 2
ML061030324
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 04/13/2006
From: Kalyanam N
NRC/NRR/ADRO/DORL/LPLG
To: Riccardella P
Structural Integrity Associates
Kalyanam N
References
TAC MD0191
Download: ML061030324 (5)


Text

April 13, 2006 Peter C. Riccardella, Senior Associate and Chief Technology Officer Structural Integrity Associates, Incorporated 6855 S. Havana Street Suite 350 Centennial, CO 80112-3868

SUBJECT:

STRUCTURAL INTEGRITY ASSOCIATES, INC. - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE FOR SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2 (TAC NO. MD0191)

Dear Mr. Riccardella:

By letter dated March 17, 2006, Southern California Edison submitted an affidavit dated March 14, 2006, executed by you, requesting that the information contained in the following drawings be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390:

1. SONGS-08Q-01, Revision 1 (3 Sheets) SO23-919-D137
2. SONGS-08Q-02, Revision 0 (3 Sheets) SO23-919-D139 Since a nonproprietary copy of this document was not submitted, the entire package sent by you, except the drawings identified above, have been placed in the Nuclear Regulatory Commission's (NRC's) Public Document Room and added to the Agencywide Documents Access and Management System Public Electronic Reading Room.

The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by SI [Structural Integrity Associates, Inc.].

(ii) The information is of a type customarily held in confidence by SI and not customarily disclosed to the public.

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of SI's competitors without license from SI constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data

P. Riccardella secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of SI, its customers or suppliers.

(e) It reveals aspects of past, present, or future SI or customer funded development plans and programs of potential commercial value to SI.

(f) It contains patentable ideas, for which patent protection may be desirable.

We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of your statements, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure.

Therefore, the four drawings marked as proprietary, will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended.

Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises, we may send copies of this information to our consultants working in this area. We will, of course, ensure that the consultants have signed the appropriate agreements for handling proprietary information.

If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You also should understand that the NRC may have cause to review this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure.

If you have any questions regarding this matter, I may be reached at 301-415-1480.

Sincerely,

/RA/

N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-361 cc: See next page

P. Riccardella secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of SI, its customers or suppliers.

(e) It reveals aspects of past, present, or future SI or customer funded development plans and programs of potential commercial value to SI.

(f) It contains patentable ideas, for which patent protection may be desirable.

We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of your statements, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure.

Therefore, the four drawings marked as proprietary, will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended.

Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises, we may send copies of this information to our consultants working in this area. We will, of course, ensure that the consultants have signed the appropriate agreements for handling proprietary information.

If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You also should understand that the NRC may have cause to review this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure.

If you have any questions regarding this matter, I may be reached at 301-415-1480.

Sincerely,

/RA/

N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-361 cc: See next page DISTRIBUTION:

PUBLIC RidsAcrsAcnwMailCenter RidsNrrLALFeizollahi LPLIV r/f RidsNrrDorlLplg (DTerao) RidsOgcRp RidsRgn4MailCenter (TPruett) COsterholtz RidsNrrPMNKalyanam Kgruss RidsNrrDorlDpr ACCESSION NO:

OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DCI/CFEB NRR/LPL4/BC NAME NKalyanam LFeizollahi KGruss DTerao DATE 3/30/06 3/30/06 4/5/06 4/13/06 OFFICIAL RECORD COPY

San Onofre Nuclear Generating Station Units 2 and 3 cc:

Mr. Daniel P. Breig Director, Radiologic Health Branch Southern California Edison Company State Department of Health Services San Onofre Nuclear Generating Station P.O. Box 997414, MS 7610 P. O. Box 128 Sacramento, CA 95899-7414 San Clemente, CA 92674-0128 Resident Inspector/San Onofre NPS Mr. Douglas K. Porter, Esquire c/o U.S. Nuclear Regulatory Commission Southern California Edison Company Post Office Box 4329 2244 Walnut Grove Avenue San Clemente, CA 92674 Rosemead, CA 91770 Mayor Mr. David Spath, Chief City of San Clemente Division of Drinking Water and 100 Avenida Presidio Environmental Management San Clemente, CA 92672 P. O. Box 942732 Sacramento, CA 94234-7320 Mr. James T. Reilly Southern California Edison Company Chairman, Board of Supervisors San Onofre Nuclear Generating Station County of San Diego P.O. Box 128 1600 Pacific Highway, Room 335 San Clemente, CA 92674-0128 San Diego, CA 92101 Mr. James D. Boyd, Commissioner Mark L. Parsons California Energy Commission Deputy City Attorney 1516 Ninth Street (MS 31)

City of Riverside Sacramento, CA 95814 3900 Main Street Riverside, CA 92522 Mr. Ray Waldo, Vice President Southern California Edison Company Mr. Gary L. Nolff San Onofre Nuclear Generating Station Assistant Director - Resources P.O. Box 128 City of Riverside San Clemente, CA 92764-0128 3900 Main Street Riverside, CA 92522 Mr. Brian Katz Southern California Edison Company Regional Administrator, Region IV San Onofre Nuclear Generating Station U.S. Nuclear Regulatory Commission P.O. Box 128 611 Ryan Plaza Drive, Suite 400 San Clemente, CA 92764-0128 Arlington, TX 76011-8064 Mr. Michael R. Olson San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 March 2006

San Onofre Nuclear Generating Station Units 2 and 3 cc:

Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899 Mr. A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. Richard M. Rosenblum Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 March 2006