ML19263D726
| ML19263D726 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/09/1979 |
| From: | Noel M SOUTHERN CALIFORNIA EDISON CO. |
| To: | Boyd R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7904130195 | |
| Download: ML19263D726 (12) | |
Text
{{#Wiki_filter:.. ,. v. ~. Southern California Edison Company 3a P O SOX 400 2 2 44 W ALN U T GROV E AVE N U E ROSEMEAD C ALIFORNI A 917 70 " " ~ " ' uncuart L. sor t March 9, 1979 ,....a... u ni o w.. Director of fluelear Reactor Regulations U. S. I'uclear Regulatory Commission Washington, D. C. 20555 Attn: fir. Roger Boyd, Director Division of Proj ect Management Re: Palo Verde !!uclear Generating Station Units 4 & 5 - Docket 1I03. STri-50-592/593
Dear Mr. Boyd:
In compliance with your request for additional financial information, enclosed herewith are documents entitled " Sources of Funds for System-Wide Construction Expenditures During Period of Construction of Subj ect !!uclear Plant" and " Projected Construction Capital Requirements (1980-1990)" for applicant Southern California Edison Company together with a list of assumptions made therein. Pursuant to 10 C,F.R. Section 2.790 (1977), Southern California Edison Company hereby requests that the above documents and the accompanying assumptions be withheld from public disclosure and not be made available for inspection and copying in the ?!RC Public Document Room. This request for non-disclosure is accompanied by an affidavit in compliance with 10 C.F.R. 2.790 (b) (1). Pursuant to 10 C.F.R. Section 2.790 (c), Southern California Edison Company requests notice and the opportunity to withdraw the above document in the event this request for non-disclosure is denied. Section 2.790 (b) (1) requires a person seeking non-disclosure to incorporate in a separate paper any part of the data cought to be withheld. In keeping with the intent of this requirement, non-proprietary financial data is transmitted under separate Cover. Sincerely, SOUTHERI: CALIFCP: IIA ZDISCII CCMPA:'Y / e9f g Treasurer 40 \\ Attachments \\ g#
AFFIDAVIT PURSUANT TO 10 CFR 2.790 ) SOUTHERN CALIFORNIA EDISON COMPANY ) SS.: ) I, M.L. Noel depose and say that I am an officer, to wit Treasurer, of Southern California Edison Company " Applicant" and authorized to make this affidavit and have reviewed or caused to be reviewed the Information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Southern California Edison Company for withholding this Information. The Information for which proprietary treatment is sought is contained in the following documents: a. " Sources of Funds for System-Wide Construction Expenditures During Period of Construction of Subject Nuclear Plant" for applicant Southern California Edison Company together with a list of assumptions made therein. b. " Projected Construction Capital Requirements (1980-1990)".
s . This Information has been appropriately designated as confidential. I have personal knowledge of the criteria and procedures utilized by Applicant in designating the Information as a trade secret, privileged or as confidential commercial or financial information. Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of Commission's regulations, the following is furnished for consideration by the Commission in determining whether the above referenced Information sought to be withheld from public disclosure should be withheld. 1. The Information sought to be withheld from public disclosure is the Information entitled " Sources of Funds for System-Wide Construction" and " Projected Construction Capital Requirements (1980-1990)" together with assumptions applicable thereto. 2. The Information consists of financial and commercial projections and other similar data concerning the Applicant's operations which Applicant uses for internal planning of its activities and which results in a competitive advantage to Applicant. 3 The information is of a type customarily held in confidence by Applicant and not custcmarily disclosed to the public. Applicant has a rational basis for determining
the types of information customarily held in confidence by it and, in that connection, utilises a system to determine when and whether to hold certain types of information in confidence. The details of the aforementioned Information were provided to the Nuclear Regulatory Commission via letter dated March 9, 1979 from M.L. Noel to Mr. Roger Boyd, Director of Division of Project Management. This system was applied in determining that the subject Information described herein is proprietary. 4. The Information is being transmitted to the Commission in confidence under the provisions of 10 CER 2.790 with the understanding that it is to be received in confidence by the Commission. 5. The Information, to the best of my knowledge and belief, is not available in public sources, and any i disclosure to third parties has been made pursuant to reEulatory provisionc or proprietary agreements which provide for maintenance of the information in confidence. 6. Public disclosu'o of the Information is likely to csuse substantial harm to the competitive position of Applicant because: a. Applicant must compete with other companies within its industry for necessary capital to maintain its current and projected levels of operation.
~ . b. The Information, if publicly desiminated, could give rise to expectations in the financial community which, if not realized, might jeopardize Applicant's ability to raise necessary capital thus harming its competitive position. c. The development of the Information by Applicant required several hundred man-hours of effort and substantial expense. The means utilized by Applicant in producing the Information are to the best of my knowledge, unique and a competitor of Applicant in the financial markets would have to undergo similar expenses in compiling equivalent information. d. Notwithstanding the fact that Applicant has included in the Information assumptions upon which its conclusions are based and stated that the Information is subject to change at any time, the public disclosure of the Information would result in its being available to participants in the financial markets who may rely on the conclusions set forth in the Information without regard to the underlying assumptions and the probability that said assumptions will change. Such reliance could subject the Applicant to burdensome litigation which would adversely affect Applicant's competitive position.
. The public disclosure of the Informa ion could e. adversely affect the procedures through which Applicant's future operations and product pricing expectations are determined resulting in a competitive disadvantage to Applicant. Further the deponent sayeth not. SOUTHERN CALIFORNIA EDISON COMPANY i i / l '[ BY / o / M. L. NOEL Treasurer Subscrited and swcrn to before me this dayof. [AdC.h... 197.7. . k,............ lotary Public i c...., a t......... u.. a ce.m... p,im, ni,rie, a ni u.na.wewaw:nen..naxamx ag CFFICI AL SEAL 3 -.~ ! Lia-- DOROTHY V. ROTH I 9 Ca%;* NOTARY PUELIC-CAllFORNIA j j $$'pp PF.iNCIPAL CFFICE IN g i LOS ANGELES COUNTY = $ Vy Cernm:ssica Expires February 13. 1983 i use uma.mnunumi.n =,w A}}