ML20203G613

Affidavit of Rg Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure

ML20203G613
Person / Time
Site:	Susquehanna
Issue date:	01/26/1998
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 9902190388
Download: ML20203G613 (3)

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• e% e AFFIDAVIT OF ROBERT G. BYRAM l

I, Robert G. Byram, Sr. Vice President-Generation / Chief Nuclear Officer of PP&L Inc. ("PP&L*), do hereby affirm and state:

1. I am an officer of PP&L authorized to execute this affidavit on its behalf. I am further authonzod to review informabon submitted to the Nuclear l Regulatory Commission and apply for the withholding of i Jurination from disclosure.

2. PP&L requests that certain portens of the documern attached hereto ("PP&L Response") be withheld from public disclosure urkier the provisions of 10 C.F.R. 2.790(a)(4) and (a)(6). This document deletes the portit.ms sought to be withheld.

3. The PP&L Response contains the results of intomat investigative activities that constitute confidential commercial informabon that should be withheld

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

i 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.

5. There is a rational basis for holding this informabon in confidence.

Confidential treatment of such information encourages frank and open intomal  !

invesbgabons. l

6. Disclosure of the complete document would result in the details of this intamal investigation being revealed. Such disclosure would adversely affect the l l

future effectiveness of the Company's ability to invesbgate potential wrongdoing by i its employees.

7. The employees interviewed did not expect publication of the results '

of their interviews to the public.

8. Individual employees would be reluctant to candidly discuss matters l

! with the Auditing Department and other individuals conducting invesbgabon which would in tum undermine the employees' trust in PP&L's intamal auditors and other  ;

investigators. The credibility of the Company'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 chilling effect on futura l i investigations. ,

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9. The PP&L Response also involves personal and pnvacy issues, the

, disclosure of which could unreasonably harm individual employees.

l j 10. This informabon 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.

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11. Public disclosure of this informanon would cause substantial harm to the competitive possbon of PP&L, because such informaeon could be used by i

) others to harm it and thereby gain a compebbve advantage over it. l i

PP&L, INC. )

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Subscribed and swom before me, a Notary Public in and for the .

Commonwealth of Pennsylvania l

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JAfGCE hL M Netwy PWec of Asensen, LaNgh Coweg PA My Eighte Jwie 11,2001  ;

ISSUES TO CONSIDER FOR DISCRETION O Problems categorized at Severity Level I or 11.

I O Case involves overexposure or release of radiological materialin excess.of NRC requirements.

O Case involves particularly poor licensee performance.

O Current violation is directly repetitive of an earlier violation.

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O Excessive duration of the problem resulted in a substantial increase in risk.

i l 0 Case may involve willfulness. include information to address whether or not the l region has had discussions with 01 regarding the case, whether or not the matter has been entered into the allegation system as staff suspected wrongdoing, and whether or not 01 intends to initiate an investigation. Include a description, as applicable, of the facts and circumstances that address the aspects of negligence, careless disregard, willfulness, and/or management involvement.

i O Licensee made a conscious decision to be in noncompliance in order to obtain an economic benefit.

O Case involves the loss of a source. (Note whether the licensee self-identified and reported the loss to the NRC.)

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O Licensee's sustained performance has been particularly good.

O Discretion should be exercised by escalating or mitigating to ensure that any j proposed civil penalty reflects the NRC's concem regarding the violation at issue

! and that it conveys the appropriate message to the licensee.

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