ML20203G603

Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure

ML20203G603
Person / Time
Site:	Susquehanna
Issue date:	12/04/1997
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:
Shared Package
ML20203G588	List: ML20203G582 ML20203G603 ML20203G607 ML20203G613 PLA-4818, Forwards Redacted Version of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 & Affidavit Pursuant to 10CFR2.790 Justifying That Redacted Portions Be Withheld from Public Disclosure.Without Rept
References
FOIA-99-36 NUDOCS 9902190385
Download: ML20203G603 (2)

Text

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AFFIQAYlT OF RQSERT G. BYRAM I, Robert G. Byram, Sr. Vice President-Generation / Chief Nuclear

- Officer of Pennsylvania Power & Light Company ("PP&L"), do hereb~y affirm and state:

1. I r.m an officer of PP&L authorized to execute this affidavit on its behalf. I am further authorized to review information submitted to the Nuclear Regulatory Commission and apply for the withheiding of information from disclosure.

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2. PP&L requests that certain portions of the document attached hereto ("PP&L Response") be withheld from public disclosure under the provisions of 10 C.F.R. 2.790(a)(4) and (a)(6).

3.' The PP&L Response contains the results of intemal investigative activities that constitute confidential commercial information that should be withheld -

under 10 C.F.R. 2.790(a).

~ 4. This information has been held in confidence by PP&L. To the extent that PP&L has shared this information with others, it has done so on a confidential basis. l

5. There is a rational basis for holding this information in confidence Confidential treatment of such information encourages frank and open internal investigations.

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6. Disclosure of the attached document woul:1 result iri the details of I this intamal investigation being revealed. Such disclosure would :dversely affect the future effectiveness of the Company's ability to investigate potential wrongdoing by its employees.

7. The employees interviewed dio not expect publication of the results of theirinterviews to the public.

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8. Individual employees would be reluctant to candidly discuss matters with the Auditing Department and cther individuals conducting investigation which would in tum undermine the employees' trust in PP&L's intemal auditors and other investigators. The credibility of the Cornpany's investigative process would also be l

diminished. As a result, the govemment's ability to obtain similar information in the future would be impaired. Such disclosure would have a chi!!ing effect on future investigations.

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9. The PP&L Response also involves. personal and privacy issues, the disclosure of which could unreasonably harm individual employees.

10. This information is being transmitted and received in confidence. It is not available from public sources and could not be gathered readily from other publicly available information.

11. Public disclosure of this information would cause substantial harm to the competitive position of PP&L. because such information could be used by others to harm it and thereby gain a competitive advantage over it.

PENNSYLVANIA POWER & LIGHT COMPANY is -

Rob .B am -

I Subscribed and swom before me, a Notary Public in and for the Commonwealth of Pennsylvania this 4

• day of B--- =% 1997.

p A YA T aa a-NOTARIAL SEAL l JANICE M. REESE. Notary Pubsc Cahr W Allentown. Lohsgh County, PA J l My 6 .- '=. Emres June M. 200g _ _ _