ML061030324

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Structural Integrity Associates, Inc. - Request for Withholding Information from Public Disclosure for San Onofre, Unit 2 (TAC No. MD0191)
ML061030324
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 04/13/2006
From: Kalyanam N K
NRC/NRR/ADRO/DORL/LPLG
To: Riccardella P C
Structural Integrity Associates
Kalyanam N
References
TAC MD0191
Download: ML061030324 (5)


Text

April 13, 2006Peter 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 FORWITHHOLDING 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 datedMarch 14, 2006, executed by you, requesting that the information contained in the followingdrawings be withheld from public disclosure pursuant to Title 10 of the Code of FederalRegulations (10 CFR) Section 2.390:1. SONGS-08Q-01, Revision 1 (3 Sheets) SO23-919-D1372. SONGS-08Q-02, Revision 0 (3 Sheets) SO23-919-D139Since a nonproprietary copy of this document was not submitted, the entire package sent byyou, except the drawings identified above, have been placed in the Nuclear RegulatoryCommission's (NRC's) Public Document Room and added to the Agencywide DocumentsAccess and Management System Public Electronic Reading Room.The affidavit stated that the submitted information should be considered exempt frommandatory public disclosure for the following reasons: (i)The information sought to be withheld from public disclosure is ownedand 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 notcustomarily 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 (orcomponent, structure, tool, method, etc.), the application of which data P. Riccardella- 2 -secures a competitive economic advantage, e.g., by optimization orimproved marketability.(c)Its use by a competitor would reduce his expenditure of resources orimprove 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 fundeddevelopment plans and programs of potential commercial value to SI.(f)It contains patentable ideas, for which patent protection may bedesirable.We have reviewed your application and the material in accordance with the requirements of10 CFR 2.390 and, on the basis of your statements, have determined that the submittedinformation 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 disclosurepursuant 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 anddirectly 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 futuresuch 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 reviewthis 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 determinationadverse 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 ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-361 cc: See next page P. Riccardella- 2 -secures a competitive economic advantage, e.g., by optimization orimproved marketability.(c)Its use by a competitor would reduce his expenditure of resources orimprove 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 fundeddevelopment plans and programs of potential commercial value to SI.(f)It contains patentable ideas, for which patent protection may bedesirable.We have reviewed your application and the material in accordance with the requirements of10 CFR 2.390 and, on the basis of your statements, have determined that the submittedinformation 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 disclosurepursuant 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 anddirectly 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 futuresuch 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 reviewthis 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 determinationadverse 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 ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-361 cc: See next pageDISTRIBUTION

PUBLIC RidsAcrsAcnwMailCenterRidsNrrLALFeizollahiLPLIV r/f RidsNrrDorlLplg (DTerao)RidsOgcRpRidsRgn4MailCenter (TPruett) COsterholtzRidsNrrPMNKalyanamKgrussRidsNrrDorlDprACCESSION NO: OFFICENRR/LPL4/PMNRR/LPL4/LANRR/DCI/CFEBNRR/LPL4/BCNAMENKalyanamLFeizollahiKGrussDTeraoDATE3/30/063/30/064/5/064/13/06OFFICIAL RECORD COPY March 2006San Onofre Nuclear Generating Station Units 2 and 3 cc:Mr. Daniel P. Breig Southern California Edison Company San Onofre Nuclear Generating Station

P. O. Box 128 San Clemente, CA 92674-0128Mr. Douglas K. Porter, EsquireSouthern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770Mr. David Spath, ChiefDivision of Drinking Water and Environmental Management P. O. Box 942732 Sacramento, CA 94234-7320Chairman, Board of SupervisorsCounty of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101Mark L. ParsonsDeputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522Mr. Gary L. Nolff Assistant Director - Resources City of Riverside 3900 Main Street Riverside, CA 92522Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064Mr. Michael R. OlsonSan Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548Director, Radiologic Health BranchState Department of Health Services P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414Resident Inspector/San Onofre NPS c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemente, CA 92674Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92674-0128Mr. James D. Boyd, CommissionerCalifornia Energy Commission 1516 Ninth Street (MS 31)

Sacramento, CA 95814Mr. Ray Waldo, Vice PresidentSouthern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92764-0128Mr. Brian KatzSouthern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92764-0128 March 2006San Onofre Nuclear Generating Station Units 2 and 3

cc:Mr. Steve HsuDepartment of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899Mr. A. Edward SchererSouthern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92674-0128Mr. Richard M. RosenblumSenior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station

P.O. Box 128 San Clemente, CA 92674-0128