ML20072R099
| ML20072R099 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 03/07/1983 |
| From: | Turley K ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| REF-SSINS-5340 NUDOCS 8304050448 | |
| Download: ML20072R099 (7) | |
Text
Arizona Public Service Company P o BOX 21%6 e PHOENIX, ARl2ONA 85036 KEITH TURLEY csamuan ano ca.u titcume omcta March 7, 1983 Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Re:
1)
ANPP-22851, dated 1/28/83 2)
ANPP-22852, dated 1/28/83 3)
ANPP-22943, dated 2/9/83 4)
ANPP-22944, dated 2/9/83
Dear Mr. DeYoung:
In response to your January 26, 1983 letter, the senior management of Arizcna Public Service Company (APS) as Project Manager and Operating Agent for the Palo Verde Nuclear Generating Station has since the inception of the project been deeply involved in all the activities of the project and in particular those related to cafety and quality.
Direct responsibility for engineering, design, construction and related quality assurance activities has been the singular respon-sibility of the Vice President of Nuclear Projects Management who reported until recently to the Executive Vice President of Operations.
As the project moved into the startup and preoperational test phase, we have also assigned a Vice President of Nuclear Operations full time to oversee and coordinate these important activities.
He also reported until recently to the Executive Vice President of Operations.
In October of 1982 the Executive Vice President of Operations was relieved of all other responsibilities and is responsible full time for all activities related to the Palo Verde Project.
In his new capacity as Executive Vice President for the Arizona Nuclear Power Project (ANPP) he reports directly to me in my capacity as Chairman of the Board and Chief Executive Officer of APS.
The Executive Vice President for the Arizona Nuclear Power Project, who by the way is also a member of the APS Board of Directors, has reporting to him the Vice President, Nuclear Operations and the Vice President, Nuclear Projects Management as well as the Corporate Quality Assurance Manager.
This ongoing full time commitment of senior management resources gives me confi-dence that our conmitments to the public and our stockholders regarding safety and quality will be diligently carried out.
We, as you, have been concerned with recent revelations regarding fraudulent activities by equipment suppliers. Upon becoming aware of the problem with material supplied by Ray Miller, Inc., we immediately advised our two major contractors, Ref 1 and 2,
copies attached, of our concerns and asked them to investigate the situation.
Upon receipt of IE Information Notice 83-01: Ray Miller, Inc.,
this was also transmitted to our major contractors, Ref 3 and 4,
copies attached, as supplementary information to our previous request.
The results of these in-vestigations will be documented and any corrective action which may be found necessary will be implemented.
b 8304050448 830307 PDR ADOCK 05000528 A
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Mr. Richard C. DeYoung Page 2 March 7, 1983 i
This is the general procedure that we follow to disposition any matter of which we become aware, which could have a potential impact upon the safety or quality of PVNGS.
We believe it has been effective in assuring that the design, engineer-j ing, construction, startup and operation of PVNGS has been and will be conducted in a safe and quality manner.
In conclusion, we believe that the management of APS has recognized and accepted its responsibility for the safety and quality of PVNGS, and has aggressively pursued these responsibilities.
I fully agree with you that the responsibility is with the utility to fully demonstrate that all safety issues are addressed and resolved.
Very truly yours,
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Attachments cc:
O. M. De Michele l
T. G. Woods, Jr.
l E. E. Van Brunt, Jr.
G. C. Andognini J. A. Roedel i
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AHIZCMA NUCLEAR POWER PROJECT hj Post Office Bon 21666 Phoenix, Arizona 85036
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- s. o 0-January 28, 1933 A!!PP-22351-BSK/ JAR
!!r. U. II. Wilson Project 11anager Bechtel Power Corporation 11443 South Lakewood Boulevard Douney, California
Subject:
!!ismarked Steel Purchased From Ray !! iller, Inc.,
Calduell, !!ew Jersey File: 33-001-000 D.23
Dear 3111:
Recent articles published in the media discussed mismarked steel purchased from Ray :lille, Inc., of West Caldwell,?Iew Jersey. We understand the fiRC will issue this ucek preliminary notificatione to nuclear utilities addressing this area.
At issue are batches of uismarked steel that went either directly to utilities or to companies that make parts used in liuclear Plants, such as small diameter pipe fittings and pipe tubes. The miscarkings include:
welded and draun tubing that was marked and sold as seamless tubing; orders for 304L, a stainless steel with low carbon content, were filled with 304, which has standard carbon content; some foreign-made steel was sold as domestic; and sone small pipe fittings, like plugs for a 1/4 to 3/4 inch pipe with rating of 150 pounds per square inch, were sold as having a rating of 3,000 PSI.
For PViOS please determine:
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If furnished, uhere at PV:GS is the material located?
3.
If furnished, what actions are planned to verify the adequacy of the material and uhen is the scheduled date for completion?
4.
If material at PV::0S is found inadequate, what are your plans for replacement in an expeditious manner?
ANPP participants: Arizona Public Service Company. Salt River Project. Public Service Company of New Mexico
. El Paso Electric Company. Southern California Edison Company
6 0
- 1r. C. F. Ferguson January 28, 1933 Project !!anager AIPP-22352-BSIUJAR Page 2 Your response to Iteu 1 is requested by February 7, with the complete response to this letter due no later than February 21, 1933.
Very truly yours, C)
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CCLC ' d mLL E. E. Van Brunt, Jr.
APS Vice President Nuclear Projects Management A:iPP Project Director EEVBJr/ 3SK:db cc:
T. G. Uoods, Jr.
G. C. Andognini J. A. Roedel J. R. Synum J. E. Kirby J. Vorees J.11. Allen J. IIouchen U. G. Singham U. J. Stubblefield U. C. Ide C. N. Russo C. E. Pankonin D. R. liawkinson
ARIZCNA NUCLEAR POWER PROJECT eb
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Post Office Box 21666 Phoenix. Arizona 85036 a
January 28, 1903 A;PP-22852-BSK/ JAR Ilr. C. F. Ferguson Project Manager C-E Power Systems Combustion Engineering, Inc.
1000 Prospect 11111 Road Windsor, Connecticut 05093
Subject:
!!iscarked Steel Purchased From Ray !! iller, Inc.,
Caldwell, New Jersey File: 83-001-000 D.23
Dear Chuck:
Recent articles published in the media discussed mismarked steel purchased from Ray liller, Inc., of West Caldwell, New Jersey. Ue understand the fiRC will issue this week preliminary notifications to nuclear utilities addressing this area.
At issue are batches of miscarked steel that went either directly to utilities or to companies that make parts used in Nuclear Plants, such as small diameter pipe fittings and pipe tubes. The mismarkings include:
welded and drawn tubing that was marked and sold as seamless tubing; orders for 304L, a stainless steel with low carbon content, were filled with 304, which has standard carbon content; some foreign-made steel was sold as domestic; and some small pipe fittings, like plugs for a 1/4 to 3/4 inch pipe with rating of 150 pounds per square inch, were sold as
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having a rating of 3,000 PSI.
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.Fo,r_,PV:'GS pleasp, de,termin_e:
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1.
Did Ray Ililler, Inc.
, directly or indirectly, for use at PVNGS?
2.
If furnished, where at PVNOS is the material located?
3.
If furnished, what actions are planned to verify the adequacy of the material and when is the scheduled date for completion?
4.
If material at PVNOS is found inadequate, what are your plans for replacement in an expeditious manner?
ANPP participants: Ari:cna Public Service Company. Salt River Project. Public Service Company of New Me
. pi poen gron,;n enmnens,. e n... s o,- e, m -- ;, e s :--- c
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!!r. W. II. Uilson January 28, 1933 Pro ject :lanager X;PP-22331-3SK/ JAR Page 2 Your response to Iten 1 is requested by February 7, with the complete response to this letter due no later than February 21, 1933.
Very uly yours,
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E. E. Van Brunt, Jr.
APS Vice President Ildelear Projects !!anagement A?;PP Project Director EEV3Jr/BSK:db cc:
T. G. Uoods, Jr.
G. C. Andognini J. A. Roedel J. R. Bynua J. E. Kirby J. Vorees J. I-I. Allen J. ilouchen U. G. Bingham U. J. Stubblefield U. E. Ide C. :?. Russo G. E. Pankonin D. R. llawkinson
ARIZONA NUCLEAR POWER PROJECT 3
Post Office Box 216( hoenix. Arizona 85036 February 9, 1983 ANPP-22944-JAR /TGW Mr. W. H. Wilson Project Manager Bechtel Power Corporation 11445 South Lakewood Boulevard Downey, California
Subject:
Mismarked Steel Purchased from Ray Miller, Incorporated of Caldwell, New Jersey File:
83-001-000 D.28
Reference:
Letter ANPP-22851-BSK/ JAR, dated January 28, 1983, same subject
Dear Bill:
Enclosed, is additional information which might assist you in your response to the referenced letter.
Very truly yours D.
4 E. E. Van Brunt, Jr.
APS Vice President Nuclear Projects ANPP Project Director EEVBJr/ JAR:ske Enclosure (IE Information Notice No. 83-01) cc:
T. G. Woods, Jr.
G. C. Andognini J. A. Roedel J. R. Bynum J. E. Kirby J. Vorces J. M. Allen J. Houchen W. C. Bingham W. J. Stubblefield W. E. Ide C. N. Russo C. E. Pankonin W. F. Quinn i
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NUCLEAR REGULATORY COMMISSION 0 M' -
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0FFICE OF INSPECTION AND ENFORCEMENT
. WASHINGTON, D. C.
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January 26, 1983 QllL 4
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IE INFORMATION NOTICE NO. 83-01:
RAY MILLER, INC.
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Addressees:
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All holders of a nuclear power reactor or fuel facility operating license (OL) or construction permit (CP).
Purcose:
This information notice is provided as an early notification of a potentially significant problem pertaining to fraudulent products that may have been sold to nuclear industry companies by Ray Miller, Inc. This problem may affect both PWR and BWR facilities.
The Nuclear Regulatory Commission staff is reviewing the problem and its effects.
If the evaluation so indicates, the NRC may request explicit licensee or CP holder action.
In the interim, we expect the addressees of this information notice to review the information herein for applicability to their facilities. No specific action or response is required at this time.
Descriotion of Circumstances:
.A.
Background
During November 1982, the Nuclear Regulatory Commission became aware that Ray Miller, Inc., Charleston, West Virginia had been systematically
' defrauding its customers, including some nuclear industry companies, by marketing products under false pretense, i.e., the markings on cheaper, lower quality products were altered to make them appear to be of higher
,, quality.
Former company officers pleaded guilty in the US District Court in Charleston, West Virginia to 10 felonies: six counts of mail fraud and four counts of wire fraud.
Ray Miller, Inc. was a New Jersey corporation with its main office located
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in West Caldwell New Jersey and with branch offices in Charleston, West Virginia; Decatur, Georgia; Buf falo, New York; and Skokie, Illinois.
The Ray Miller office in Charleston, West Virginia was stated to be the only office with equipment capable of making alterations of markings on materials.
The firm had been under investigation by special FBI ageats for three years before prosecution by the Office of U.S. Attorney, Charleston, West Virginia.
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- 7 IN 83-01
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January 26, 1983 Page 2 of 4
~ The precise nu:tbrir of nuclear-related businesses that may have been defrauded by Ray Miller, Inc. remains an unknown.
Records are incomplete and the situation is further complicated by the firm ceasing to operate
_.._and. filing for reorganization under Chapter 11 of the bankruptcy statutes.
An Assistant U.S. Attorney has determined that Ray Miller may have shipped substandard products to at least 125 companies in the 19 year period I
before the FBI began its probe in July 1979.
Under the terms of the plea agreement, ; Ray Miller, Inc. is to notify, by February 1,1983, all com-(
panies with which it had business dealings, concerning the firm's frau-dulent practices.
..i Some of the nuclear industry companies appearing on an FBI generated list of Ray Hiller customers for the year 1979 include Babcock and Wilcox,..
e, Combustion Engineering, Goodyear Atomic, Tennessee Valley Authority,
' Virginia Electric tod Power (VEPCO), and' Allied Chemical (at Barnwell).
VEPCO and Barnwell are aware of the Ray Miljer problem.
VEPC0 has placed suspect frsudulent material, which had not been installed, on hold.
B.
Discus'ston Specifically, the scheme to defraud as pracciced by Ray Miller, Inc. from
. app;oxmiately 1960 to 1979 was exposed by an extensive investigation
- . conducted by th'a Federal Bureau of Investigation..The primary practices.
which formed that scheme, as. detailed by the FBI, are as follows:
4
- 1.
' Markings on pipes and nipples indicating the foreign, country where the product was, manufactured were removed and the pipes and nipples were sold as domestic-made products.
2.
Stainless steel (304'and 316) couplings, flanges, and bushings
..'having standard carbon content were altered by imprinting an "L",
Y' making the marking on couplings, flanges and bushings appear'as low
" carbon content ma,terials.
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Falselyn'otariz~'ddocumentswerepreparedwithb5113ngs, certifying _
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' they were not.
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Welded and drawn tubing was altered by removing the markings "WD" from this product and it was sold as seamless tubing.,
a The Ray Miller records were made available to the NRC after the company officers who pleaded guilty were sentenced on December 23, 1982. On i
January 6 and 7, 1983, members of the NRC met with the FBI and the Assistant U.S. Attorney in. Charleston, West Virginia to discuss the Ray Millei, Inc. case and to review a sample of the 29 boxes of records currently in the custody of the FBI.
These records cover the period from 1975 to.1979. After 1979, Ray Miller, Inc. apparently ceased its frau-dulent practices.
The NRC is checking on the availability of records that pre-date 1975.
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i IN 83-01 January 26, 1983 Page 3 of 4 During the sampling of records by the NRC, the following additional documentation of product substitution was identified: machined items
~ were sold as forged ones, and materials with a low capacity to withstand pressure, i.e.,150 psi pipe plugs, were sold as materials capable of withstanding much greater pressures, e.g., 3000 psi pipe plugs.
Some of the invoices reviewed by HRC representatives and used as undeniable evidence by the U.S. Attorney's Office, were found to actually have the written notation, " Remark", indicating product fraud.
Primarily, the NRC representatives attempted to ascertain the extent that Ray Miller's fraudulent practices may have impacted nuclear-related companies.
Based on a sampling of the records, the NRC staff reached the following very general conclusions:
1.
It appears that Ray Miller, Inc. supplied products to only a few companies directly involved in the nuclear power industry.
- However, the full extent to which the firm's products may be used in the nuclear industry is not known, since these products were sold to many jobbers and distributors.
2.
Most shipments which were received directly by nuclear-related businesses were relatively small.
3.
Generally, only a small portion of Ray Miller products purchased by nuclear industry companies appears to be fraudulent.
A search of the License Event Report file has been conducted by the National Science Information Center (Oak Ridge, Tennessee) for the NRC and no instances were identified in which nuclear facilities have reported deficiencies. attributed to Ray Miller, Inc. materials.
C.
Guidance Enclosedfor.youFinfoEmationandappropriateactionisalistfromthe Charlbston office of Ray Miller's customers in 1979.
As previously noted, this list resulted from an FBI investigation and may not be all inclusive, since orders made through other Ray Miller branch offices were sometimes filled by the Charleston of fice. A composite list of customers for other years is not available.
Therefore, the NRC staff suggests that, like VEPCO, other nuclear i
industry companies isolate suspect Ray Miller products which may have been received and prevent the further installation of such materials until more information is obtained.
Efforts are continuing to coordinate resources from various sectors of the nuclear. industry and 00E to provide a detailed examination of all Ray Miller records known to exist.
It is conjectured that these efforts will yield useful information for h
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IN 83-01 January 26, 1983 Page 4 of 4 placing " bounds" on the types of fraudulent materials shipped and identi-fying a more comprehensive list of buyers who may have received these materials.
.44 e dwar L.
ordan. Director
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Divisio f Emergency Preparedness and E ineering Response Office of Inspection and Enforcement Technical
Contact:
R. M. Young, IE 301-492-9672 Attachments:
1.
List of Ray Miller Customers for 1979 2.
List of Recently Issued IE Information Notices 7
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IN 83-01 January 25, 1983 Pa ge 1 of 8 The followng are cus:cr. ors of the Ray Miller Corporation for
'the year 1979; (Wi:h the exception of inter-cocpany accounts).
Alcoa Concer 7th Stree: Rd.
Rou:e 780 Alcoa Center, Pennsylvania 15069 Allegheny Power Service Corpora:icn Cabin Hill Creensburg, Pennsylvania 15601 Allied Chemical Special:y Chemicals Division North Cate, S:ste Route #1 Noendsville, West Virginia 26041 Allied General Nuclear Services Barnwell, Sou:h Carolina 29812 Appalachian Power Company P.O. Box 2021 Roanoke, Virginia 24022 Aqua Chem.. Inc.
240 Wes Capi:ol Drive eti lwauke e, Wisconsin 53212 Arge I?elded Products Alpha Industrial Park Phillipsburg, New Jers'ey 08865 Ashland Synthetic Faels. Inc.
P. O.
Bo y.
391 Ashland, Kentucky 41101 Avcer. Fibers, Inc.
Plant Road Ni t r o, 'Je s t Virginia 25143 Babcock and Vilcox Company 609 Wcrren Avenue Apollo, Pennsylvania 15613 3ASF Uy:ndotte Corporation j
Pignen:s Division 24th Stree: :nd 5th Avenue Mun:ing:ca, Wes: Virginia 25722 Peauni: Fabrics Corporation l
P. O.
Box 791 Statesville, Nor:h Carolina 28677 Bendix Corpora: ion U.S. 219 Nor:h Lewisburg, West Virginia 25901 Bethlehe Secel Corpora:icn Johns:own, Pennsylvania 15907 Brich:3n Corcorat:cn 11561 Mos:eller Road Cincinnati, Ohio 45241 i
Cal;on Corocraticr.
I P.O. Ecx 12:6 Pi::sbargh, Pennsyl.anta 15230
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. Ja nua ry 26, 1933 Page 2 of 3 Casale Industries c; South Avenue Carvood, New Jersey 07027 C. E. 2hurston and Suns, Inc.
i P.O. Box 963 P.ichmond, Virginia 23207 i
Celanese Fibers Company P.O. Box 2334 Charlotte, North Carolina 28234 Central Suppliers. Inc.
1624 Dabaun Avenue Chesapeake, Virginia 23320 Cepcda Associates, Inc.
1E23 Ltser Lano Louisville, Kentucky 40299 CF Indus tries U.S. 41 North Terra Haute, Indiana 47803 Cht: pion Papers Cha:elon International Corporation Canton Mill Canton, North Carolina 28716 Che=etren Corporation Pigments Division P.O. 3cx 2166 Huntington, West Virginia 25722 Chesapeake Corporatien of Virginia West Point, Virginia 23181 Cincinnati Fas teners Co=pany 16 Eas t 73rd Street Cincinnati, Ohio 45216 C& i/ Ci rdle r, In c.
P. O. Box 32940 Louisville, Kentucky 40232 Cofsco, Inc.
P.O. Box 134
'a'c o s te r, Ohio 44691 Cc=bustion Engineering, Inc.
M nogahelia, Pennsylvania 15063 Continental Can Cc=pany. Inc.
P.O. Box 201 Hopewell, Virginia 22860 CVI Corporation P.O. Eox 2138 Colunbus, Ohio 43216 Cyclops Industries P.O. Box 3514 South Charleston, West Virginia 25303 Dayton Power and Li;5: Cocoany C:urthouse Ple:a, Scuchwest F.C. Eox 1247 2ayt:n, Ohio 45401
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C IN 83-01 January 26, 1980 Page 3 of 8 Dusenbery T.ngineering, Inc.
Hanover Avenue Morris town, New Jersey 07960 e
Dut.* ell Tchricating 4220 West 123rd Scree:
Alsip, Illinois 6065S p
E.
I. DuPont De Nemours and Company 901 Wes t Du Pon t Avenue Belle, West Virginia 25015 Erdmann Corporation 6209 East Maxwell Avenue Evansville, Indiana 47715 F.
B. Wright Co=pany of Cincinnati, Inc.
P.O. Box 46412 Cincinnati, Ohio 45240 Fiber Industries. Inc.
1-8 5 Woodruff Road Creenville, South Carolina 29602 FMC Corporation Industrial Chemical Group P.O.
Box S127 Soutn Charleston, Wes: Virginia 25303 Forca Scien:ific, Inc.
P.O.
Box 649 l'a.rie::a, Ohio 45750 Cage Cocpany P.O. Box 1163 Pit:sburgh, Pennsylvania 15230 Cood Supply and Equipment Company 905111ani St.ee t Akron, Ohio 44311 Coodyear Ato:ic Corporation P.O. Box 628 Piketon, Ohio 45661 Coedyear Tire and Rubber Cc=pany Checical ?lant Point Pleasant, West Virginia 25550 Greene Supply Ccepany 703-33 East :tarke: Street Kingspcet. Tenn es s e e 37662 Henry Walke Co=pany P.O.
Box 1041 Norfolk, Virginia 23501 Hercules, Inc.
Radford, Virginia 24141 Hilliard Corpor.ation 100 Wes: 4th S:reet E1: ira, New York la902 Holston Defense Corpora: ion a Subsidiary of Eas:=on 1:odak Company P.O. Box 749 Kings por: Tenr.es s ee 37662
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IN 83-01 January 25, 1983 Huntingeon Alloys, Inc.
Page 4 Of 8 Rivers ce Drive Huntingten. Wes,: Virginia 25720 Indus trisi Kobber Fredue:s Company P.O. Box 107 Parkersburg, West Virginia 26101
.1TT Crinnell Corpora: ion 350 South Douglas Avenue Chillicothe, Ohio 45601 Ivorjlce Corporacion P.O. Box 650 Sharon, Pennsylvania 16146 Jabo Supply Corporation P.O. Box 238 Huntington, West Virginia 25707 J. J. Finnigsn Industries, Inc.
Old Peach Tree Road D21u th, Coor;ia 31036 Joi.n R. Und Cocpsny, In c.
P.O.
Box 392 Huntingdon, Pennsylvania 16652 Kanawha Manufacturing Co=pany P. O.
Box 1786 Charles:on, West Virginia 25326 Kelly Springfield Tire Company P.O. Box 300 Kelly Road Cu=berland, Maryland 21502
. Kentucky Pcwer Cc=pany P.O. Sox 1423 Ashland Ken:ucky 41101 Koppers Company F.O. Box 11 Follansbee, Uesc Virginia 26037 Koppert Conpany, Inc.
3y00 Sou:S Laramie A.*enue Cicero, Illinois 60550 Libbey-Owans-Ford, Company 811 Madison Avenue Toledo, Ohio 43695 3M Co pany P.O.
Box 23030 Saint Paul, Minneso:a 55133 Main Line Supply Company, Inc.
905 East Third Street Da y t o n, Chio 45402 Mid-Valley Supply Co:pany, Inc.
P.O.
Box 762 Iron:en, Ohio 45638 Mohay Chemical Corpora:ica New Martinsville, Ges: Virginia 26155
!:cdern Welding Company 1500 Eas: 12:h S: rect Owensboro, Kentucky 42301
IN 83-01 January 26, 1983 Monsanto Corporation Page 5 Of 8 Anniston, Alabama 36201 Mouldagtaph Corporation P.O. Box 485 Dunbar. Uest Virginia 25064 s
M & T Chemicals. Inc.
2316 Highland Avenue Carrollton, Xentucky 41008
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Hacional Lead Company of Chio P.O. Box 39153 Cincinnati, Ohio 45239 Hackin & Co=pany P.O. Box 25444 Richmond, Virginia 23251
!! orth American Rayon Corporation West Elk Avenue Elizabethton, Tennessee 37643 1:ovament Corporation F.O. Box 139 Kenova, West Virginia 23530 Ohio Electric Company Chio State Route 37 Cheshire, Ohio 45620 Ornet Corporation Box 176 Nannibal, Ohio 43931 Owens-Illinois Fores t Products Division Big Island, Virginia 24526 Paul Mueller Cocpany 1600 West Phelps Springfield, Missouri 65801 Paul 0. Abbe 139 Center Avenue LeFalls, New Je rsey 07424 PB1 Indusiries Steel Service Center Division P.O. Box 3373 Youngs town, Ohio 44512 Peebles Supoly Corporation P.O.
Drawer 2777
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11ewpor t News. Virginia 23602
?elt: 3rothers, Inc.
P.O. Box 12596
!!orfolk, Virginia 23502 Pennsylvania Electric Co=pany 1001 Broad Straet Johnstown, Pennsylvania 15907 Power City Plunbing and Heating. Inc.
?.0. Zox 6540 UP.eeling. West Virginia 26003
??C Industries, Inc.
industrici Chemical Division F.C. Eox 191
- eu l'artinsville, 'Jes t Virginia 26155
Precision Pd( service IN 83-01 517 Colf Mountain Road Janaury 26, 1983
- i:ro, West Virginia 25143 Page 6 Of 8 Pre-trion Stainlers Products Co=pany 4701 Hesperedies Road Tampa, Florida 33614 Process Supply, Inc.
P.O. Box 6010 Charleston, West Virginia 25302 e
Procter & Ca=ble Company Itia:t Valley Laboratories Route 27 Ross.(Butler County). Ohio 45061 Raub Supply Co=pany P.O. Box 1020 Lancaster, Pennsylvania 17604 Ray Mt.ller. Inc.
4234 Kanawna Turnpike South Charleston, Wes t Virginia 25309 Richmond Engineering Company, Inc.
P.O. Box 25129 Rich = cad, Virginia 23260 Ripco. Inc.
- P.O. Box 9366 South Charleston, Wes: Virginia Rust Engineering Co=pany P.O. Box SS7 Oak Ridge, Tennessee 37830 Samson Steel Fabricators and Machine, Inc.
?.O. Box 126 Can:on, Ohio 44701 i
Sauer, Inc.
Mechanical Contrae: cts 30- 51 s t Screet Pit:sburgh, Pennsylvania 15201 Shar;sville Steel Fabricators. Inc.
Sharp ville, Pennsylvania 16150 Shee: !!ecal Products, Inc.
794 North 6th Street Newark, New Jersey 07107 Shell Che:ical Company P.O. Box 235 Belpre, Ohio 45714 i
Sistersville Tank Works (a Division of Superior Welding Co:pany)
P.O. Box 200 Sistersville, West Virginia 26175 Southeast Paper Manciscturing Company Highway 199 Dublin, Caorgia 31021 S:andard Oil Co:pany Midland Euilding Cleveland, Chio 44115 J
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Irl 83-01 Stauffey, Chemical Company Callipotts terry, West Virginia 25515 Janaury 26, 1983 Page 7 Of 8 Stolle Corporation 1501 !"ichigan Street Sidney, Ohio 45365 5
Su=:ers Hardware and Supply Company Buffalo and Ashe Streets dox 210 Johnson City, Tennessee 37601 Taylor-Parker Company, Inc.
500 Industry Drive Ha=pton, Virginia 23361 Tennessee Eas t=an Company Division of Eas t=an Kodak Company Kin gs po r t.
Tenne s s e e 37662 Tilton Corporation 130 South Pine Lica, Ohio 45802 Tinet 100 Titanium Way Toronto, Ohio 43964 TVA Checical Stores Building Muscle Shoals Reservation Muscle Shoals. Alaba:a 35660 T. V. A. Cu=berland Steam Plant Cucberland City, Tennessee 37050
.. Union Ca:p Corporation P.O. Box 220 Cover, Ohio 44622 Union Carbide Corporation P.O. Bon 8361 Sou th Charles ton, Ucs t Virginia 25303 Virginia Electric and Power Company P.O. -Box 26666 Rich =ond.. Virginia 23261 Vulcan :unufacturing Company (a Subsidiary of Zurn Industries, Inc.)
P.O. Box 46465 Cincinnati, Ohio '45246 Walker Stainless Equipmen t 6D1 State Street New Lisbon, Wisconsin 53950 Walter N.
Yoder and Sons, Inc.
P.O. Box 1337 Cumberland, Maryland 21502 Weirton Steel (Division of National Steel Corporation)
Weirton, West Virtinta 26062 Wes tvaco (Fine Paper: Division)
Luke, l'.a ryland 21 540 W. H. Kiefaber Company P.O.
Ec:: 1226 Dayton, ' Ohio 45401 p
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{ heeling-littsburghSteelCorporation IN 83-01 4
..o. 4 vaceway senter P. o. 3o>: 116 Janaury 26, 1983 j
PI:tsburgh. Pennsylvant3 15230 age 8 Of. 8
'#!Se5 l e to Jo, ipa and Supply Company
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1 nn' Street Cincinnati, Ohio 45217 t
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J. Gill i
113 South Thocas Road.
4allmadge. Chio 44278 W. R. Crace and Company Oavisen Chemical Division 4775 Paddock Road Cincinnati, Ohio 45229 3700 Oakwood AvenueYoungstown Melding and Engineering Co:pany Yeungs town. Ohio 44509 e
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February 9, 1983 ANPP-22943-JAR /TGW Mr. Charles Ferguson Project Manager Combustion Engineering, Incorporated 1000 Prospect Hill Road Windsor, Connecticut 06095
Subject:
Mismarked Steel Purchased from Ray Miller, Incorporated of Caldwell, New Jersey File: 83-001-G00 D.28
Reference:
Letter ANPP-22852-BSK/ JAR, dated January 28, 1983, same subject
Dear Chuck:
Enclosed, is additional information which might assist you in your response to the referenced letter.
Very truly yours, COLL-1 LCL m E. E. Van Brunt, Jr.
1 APS Vice President Nuclear Projects ANPP Project Director EEVBJr/ JAR:ske Enclosure (IE Information Notice No. 83-01) cc:
T. G. Woods, Jr.
G. C. Andognini J. A. Roedel J. R. Bynum J. E. Kirby J. Vorces J. M. Allen J. Houchen W. C. Bingham W. J. Stubblefield W. E. Ide C. N. Russo G. E. Pankonin D. R. Hawkinson W. F. Quinn
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NS ( CENTDR 83-01 6
UNITED STATES 83 -O N 6
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bCeu:.unt NUCLEAR REGULATORY COMMISSION D6 OFFICE OF INSPECTION AND ENFORCEMENT
. WASHINGTON, D. C.
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k IE INFORMATION NOTICE NO. 83-01:
RAY MILLER, INC.
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O Critril Addressees:
E.?,iAT.C All holders of a nuclear power reactor or fuel facility operating license (OL) or construction permit (CP).
Purcose:
This information notice is provided as an early notification of a potentially significant problem pertaining to fraudulent products that-may have been sold to nuclear industry companies by Ray Miller, Inc. This problem may affect both PWR and BWR facilities. The Nuclear Regulatory Commission staff is reviewing the problem and its effects.
NRC may request explicit licensee or CP holder action.If the evaluation so indicates, the In the interim, we expect the addressees of this information notice to review the information herein for applicability to their facilities. No specific action or response is required at this time.
Descriotion of Circumstances:
A.
Background
During November 1982, the Nuclear Regulatory Commission became aware that Ray Miller, Inc., Charleston, West Virginia had been systematically _
' defrauding its customers, including some nuclear industry companies, by _
marketing products under false pretense, i.e., the markings on cheaper, lower quality products were altered to make them appear to be of higher
, quality.
Former company officers pleaded guilty in the US District Court in Charleston, West Virginia to 10 felonies: six counts of mail fraud and four counts of wire fraud.
Ray Miller, Inc. was a New Jersey corporation with its main' office located in West Caldwell, New Jersey and with branch offices in Charleston, West Virginia; Decatur, Jeorgia; Buffalo, New York; and Skokie, Illinois.
The Ray Miller office in Charleston, West Virginia was stated to be the l
l only of fice with equipment capable of making alterations of markings on i
materials.
The firm had been under investigation by special FBI agents for three years before prosecution by the Office of U.S. Attorney, j
l Charleston, West Virginia.
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January 26, 1983
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Page 2 of 4 The precise number of nuclear-related businesses that may have been defrauded by Ray Miller, Inc. remains an unknown.
Records are incomplete and the situation is further complicated by the firm ceasing to operate
__and. filing for. reorganization under Chapter 11 of the bankruptcy statutes.
An Assistant U.S. Attorney has determined that Ray Miller may have shipped substandard products to at least 125 companies in the 19 year period I
before the FBI began its probe in July 1979.
Under the_ terms of the plea agreement, Ray Miller, Inc. is to notify, by February 1,1983, all com-(
panies with which it had business dealings, concerning the firm's frau-dulent practices.
Some of the nuclear industry companies appearing on an FBI generated list of Ray Miller customers for the year 1979 include Babcock and Wilco 4,.
Combustion Engineering, Goodyear Atomic, Tennessee Valley Authority,
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' Virginia Electric and Power (VEPCO), and' Allied Chemical (at Barnwell).
VEPC0 and Barnwell are aware of the Ray Miller problem.
VEPC0 has placed suspect fraudulent material, which had not been installed, on hold.
8.
Discus ~sion c
Specifically, the scheme to defraud as practiced by Ray Miller, Inc. from approxmiately 1960 to 1979 was exposed by an extensive investigation
- conducted by the Federal Bureau of Investigation.,The primary practices which formed that scheme, as detailed by the FBI, are as follows:
- - 1.
Markings on pipes and nipples indicating the foreign country where the product was manufactured were removed and the pipes and nipples were sold as domestic-made products.
2.
Stainless steel (304 and 316) couplings, flanges, and bushings
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.having standard carbon content were altered by imprinting an "L",
.' r niaking the marking on couplin,gs, flanges and bushings appear 'as low
', 'i.., ' carbon content materials.
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Falsely notarized documents' were prepared with b511'ings, certifying
,,'., that th'e' materials shipped were of low carbon content when in fact s.
they were not.
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4.
Welded and drawn tubing was altered by removing the markings "WD"
'from this product and it was sold as seamless tubing.,
The Ray Miller records were made available to the NRC after the company officers who pleaded guilty were sentenced on December 23, 1982. On i
January 6 and 7, 1983, members of the NRC met with the FBI and the Assistant U.S. Attorney in Charleston, West Virginia to discuss the Ray Miller, Inc. case and to review a sample of the 29 boxes of records currently in the custody of the FBI.
These records cover the period from 1975 to 1979.
After 1979, Ray Miller, Inc. apparently ceased its frau-dulent practices.
The NRC is checking on the availability of records that pre-date 1975.
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IN 83-01 January 26, 1983 Page 3 of 4 During the sampling of records by the NRC, the following additional documentation of product substitution was identified: machined items were sold as forged ones, and materials with a low capacity to withstand
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pressure, i.e., 150 psi pipe plugs, were sold as materials capable of withstanding much greater pressures, e.g., 3000 psi pipe plugs.
Some of the invoices reviewed by NRC representatives and used as undeniable evidence by the U.S. Attorney's Office, were found to actually have the written notation, " Remark", indicating product fraud.
Primarily, the NRC representatives attempted to ascertain the extent that Ray Miller's fraudulent practices may have impacted nuclear-related companies.
Based on a samplir.g of the records, the NRC staff reached the following very general conclusions:
1.
It appears that Ray Miller, Inc. supplied products to only a few companies directly involved in the nuclear power industry.
- However, the full extent to which the firm's products may be used in the nuclear industry is not known, since these products were sold to many jobbers and distributors.
2.
Most shipments which were received directly by nuclear-related businesses were rela'.ively small.
3.
Generally, only a small portion of Ray Miller products purchased by nuclear industry companies appears to be fraudulent.
A search of the License Event Report file has been conducted by the National Science Information Center (Oak Ridge, Tennessee) for the NRC and no instances were identified in which nuclear facilities have reported deficiencies attributed to Ray Miller, Ince materials.
C.
Guidance -
Enclosed for.your information and appropriate action is a list from the Charleston office of Ray Miller's customers in 1979. As previously noted, this list resulted from an FBI investigation and may not be all inclusive, since orders made through other Ray Miller branch offices were sometimes filled by the Charleston office. A composite list of customers for other years is not available.
Therefore, the NRC staff suggests that, like VEPCO, other nuclear industry companies isolate suspect Ray Miller products which may have been received and prevent the further installation of such materials until more information is obtained.
Efforts are continuing to coordinate resources from various sectors of the nuclear industry and 00E to provide a detailed examination of all Ray Miller records known to exist.
It is conjectured that these efforts will yield useful information fc.-
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IN 83-01 January 26, 1983 l
Page 4 of 4 placing " bounds" on the types of fraudulent materials shipped and identi-fying a more comprehensive list of buyers wb may have received these materials.
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ordan, Director Divisio f Emergency Preparedness and E ineering Response Office of Inspection and Enforcement Technical
Contact:
R. M. Young, IE 301-492-9672 Attachments:
1.
List of Ray Miller Customers for 1979 2.
List of Recently Issued IE Information Notices 4
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Ir1 83-01 January 25, 1983 Page 1 of 8 The followng are cus:cr.ers of the Ray Miller Corporation for the year 1979:
(With the exception of inter-co=pany accounts).
Alcoa~Cen:er 7th Screet Rd.
Rou:e 780 Alcoa Center, Pennsylvania 15069 Allegheny Power Service Corporation Cabin Hill Greensburg, Pennsylvania 15601 f
Allied Chemical Special:y Chenicals Division Nor:h Cate, State Route #1 a
Moundsville. West Virginia 26041 Allied General Muclear Services Barnwell, Sou:h Carolina 29812 Apptlachian Power Ccepany P.O. 3cx 2021 P.ocnoke, Virginia 20022 Acua Chen., Inc.
240 Wes: Capi:ol Drive Milwaukee, Wiscunsin 53212 Arge Welded Products Alpha Industrial Park Phillipsburg, New Jersey 08865 Ashland Synthetic Faels, Inc.
?. O. 3or. 391 Ashland, Kentucky 41101 Avter. Fibers, Inc.
Plant Road Nitro, West Virginia 25143 Babcock and Wilcox Co=pany 4
609 W rren Avenue t
Apollo, Pennsylvania 15613 EASF Uy:ndotte Corporction Pigncn:s Division 24-h Street end 5th Avenue F.un:ing:en, Wes: Virginia 25722 Peauni: Tabrics ' Corporation P. O.
Box 791 Statesville, Nor:h Carolina 28677 Bendix Corpera:Lon U.S. 219 North Lewisburg, Wes: Virginia 25901 Bethlone: Steel Corpora:icn Joh,s:own, Pennsylvanta 15907 Brichton Corocratton 115i1 Mos:eller Road Cinernna:i, Ohio 45241 Cal;on Corcoration P.G. Ecx 1306 Pi::s:'argn, Pennsyl.ania 15230 i
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January 26, 1983 Page 2 of 8 Casale Industries 100~ South Avenue Car.ood, New Jersey 07027 4
C. E. Thurston and Suns. Inc.
3 P.O. Box 963 1
F.i choond, Virginia 23207 Celanese Fibers Coopany P.G. Box 2334' Charlotte, Morth Carolina 28234 Central Suppliers, Inc.
1624 Dabaun Avenue Chesapeake, Virginia 23320 Cepeda Associates, Inc.
1E23 Laser Lane
- 1. oui s ville, Kentucky 40299 CF Industries U.S. 41 North Terra 11aute, Indiana 47803 Cht: pion Papers Cha:elon International Corporation Canton Mill Canton, Nor:h Carolina 28716 Chenetron Corporation Pig =ents Division P. O. Box 2166 Huntington, West Virginia 25722 Chesapeake Corporatien of Virginia Wes t Point, Virginia 23181 1
Cincinnati Fasteners Company 16 Eas t 73rd Street Cincinnati, Ohio ' 45216 CS!/ Girdler, In c.
P.C. Sox 32940 Louisville, Kentucky 40232 Cofsco, Inc.
P.O. Box 184
- 'cos cer, Ohio 44691 Cc= bus tion Engineering, Inc.
Monogahelia, Pennsylvania 15063 Con:inental Can Ccepany. Inc.
P.O. Box 201 Hopewell, Virginia 23860 C"I Corporation F.C.
Box 213a Colunbus, Ohio 43216 Cyclops Industries
?.O. Box 8614 South Charles:en, Vest Virginia 25303 Dayton Power and Li;h: Co:cany C:urthouse Plaza, Southwest F. O.
Box 1247 2ay::n, Chio 45401 r> - - - -,-
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_.t Attachcent 1 IN 83-01 January 26, 1983 Page 3 of 8 Dusenbery T.ngineering, Inc.
Hanover Avenue 1* orris to.n, New Jersey 07960 t
DuCell T:briestina 4220 West 123rd Sirce:
i Alsip. Illinois 60658 E.
- l. Du?cnc De Nemours and Company 901 We s t Du Pon t Avenue Belle, West Virginia 25015 Erdmann Corporacion 6209 East Maxwell Avenue Evansville, Indiana 47715 F. B. Wright Co=pany of Cincinnati. Inc.
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Box 46412 Cincinnati, Ohio 45240 Tiber Industries. Inc.
' 2 5 Woodruf f Road Crecaville, South Carolina 29602 FMC Corpcra: ion Ir.dus trial Che=ical Group P.O.
Box 8127 Souen Charleston, Wes t Virginia 25303 Forma Scien:ific. Inc.
P.O. Box 649 liar ic t:a, Ohio 45750 Cage Cocpany P.O. Box 1168 Pittsburgh, Pennsylvania 15230 Cood Supply and Equip =ent Co pany 905111ani Stree t Akren, Ohio 44311 Goodyear Ato ic Corporation P.O. Box 628 Piketen, Ohio 45661 Coedyear Tire and Rubber Ccapany Checical Plan:
Poin: Pleasant, West Virginia 25550 Creene Supply Company 703-33 East ::a rke: Street Kingsper: Tennessee 37662 Henry Walke Co pany P.O.
Box 1041 Norfolk, Virginia 23501 Hercules, 'nc.
Radf ord, Virgir.ia 24141 Milliard Ccrporation 100 Wes 4th S:reet El: ira, New York 14902 Holston 2efense Corpora: ion a Subsidiary of Las:=3n l'odak Company P.C. 2cx 749 Kingsport, Tanness2e 27662
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Irl 83-01 January 25, 1933 Huntington Alloys, In c.
Riverstoe Drive Pa9e 4 Of 8 Huntingten Wes,t Virginia 25720 Industrial Kubber Product: Co=pany P.O. Son 107 Parkersburg, West Virginia 26101 ITT Grinnell Corporation 350 South Douglas Avenue Chillicothe, Ohio 45601 Ivorjlce Corporation P.O.
Box 650 Sharon, Pennsylvania 16146 Jabo Supply Corporation P.O. Box 238 Euntington, 'Jes t Virginia 25707 J. J.
Finnigan Industries. Inc.
Old Peach Tree Read Daluth, Ceor;ia 31036 Joi.n R. k'ad Cocpany, Inc.
P.O. Box 392 Huntingdon, ?ennsylvania 16652-Kanawha Manufacturing Co=pany P.O.
Box 1786 Charles ton, Wes t Virginia 25326 Kelly Springfield Tire Co pany P.O. Box 300 Kelly Road Cu=berland, Maryland 21502
. Kentucky Power Cc=pany P.O. Box 1423
-Ashland, Kentucky 41101 Koppers Co=pany P.O. Box !!
Follansbee, Wes t Virginia 26037 Koppert Co pany. Inc.
' 3900 SoucM Larcole Aeonue Cicero, Illinois 60650 Libbey-Owans-Tord, Co=peny 811 Madison Avenue Toledo, Ohio 43695 3M Co=pany P.O. Box 33030 Saint Paul, Minnesota 55133 tiain Line Supply Co=pany. Inc.
905 Eas t Third Street Da y t o n, Chio 45402 Mid-Valley Supply Company. Inc.
P.O.
Eox 762 1ronton, Chio
'563S Motay Che=ical Corporation New " art insville, West ircinia 26155
'cdern Velding Company 1500 East 12:h Street Owensboro, Kentucky 42301
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Attacument 1 IN 83-01 January 26, 1983 Monsan:o Corporation Page 5 Of 8 Anniston, Alabama 36201 Mouldagraph Corporation
?.0. Box 485 Dunbar, Ues: Virginia 25064 s
M & T Chemicals. Inc.
2316 Highland Avenue Carroll:en, Kentucky 41008 o
Itational Lead Company of Ohio P.O. Box 39153 Cincinnati, Ohio 45239 11atkin & Coopany P.O.
Box 26444 Richmond, Virginia 23251
!! orth Anerican Rayon Corpora: ion Ucst Elk Avenue Elizabeth:en, Tennessee 37643
!:ovaaon: Corporation P.O.
Box 189 Kenova. Wes: Virginia 23530 Ohio Electri: Company Ohio Sta:e Route J7 Cheshire, Ohio 45620 Orne: Corporation Box 176 Nannibal, Chio 43931 Owens-Illinois Forest Products Division Big Island, Virginia 24526 Paul Mueller Company 1600 Wes: Phelps Springfield, Missouri 65801 Paul 0. Abbe J
139 Center Avenue LeFalls. !!ew Jersey 07424 PSI Industries Steel Service Center Division P.O. Box 3373 Youngs town, Ohio, 44512 Peebles Supply Corporation P.O.
Drawer 2777
!!ewpor:. News, Virginia 23602 Pelt: 3rothers. Inc.
P.O. Box 12596
- o rfolk, Virginia 23502 Pennsylvania Electric Company 1001 3 road S:rset Johns towr., Pennsylvania 1 5907 Fower Ci:y Plunbing and Heating. Inc.
?.0. Zex 6540 Uneeling, West Virginia 26003
?.'C Indus: ries, Inc.
Indus: rial Chcaical Division P.C. 5:x 191
- ew thr:insville, West Virginia 26155
Precision P Service IN 83-01 517 Colf ::ou ain Road Janaury 26, 1983 Ni:ro. West Virginia 25143 Pa ge 6 O f 8 Pre-irion Stain 1ers Products Company 4701 Hesperedies Road Tampa, Florida 33614 Process Sueply, Inc.
P.O. Box 5010 Charleston, West Virginia 25302 e
Procter & Ca=ble Company Miami Valley Laboratories Route 27 Ross (Butler County). Ohio 45061 Raub Supply Company P.O. Box 1020 Lancas t e r, Pennsylvania 17604 Ray MLller. Inc.
4234 Kanawha Turnpike Sou:h Charleston, West Virginia 25309 Rich. end Engineering Company, Inc.
P.O. Box 2 5129 Rich:end. Virginia 23260 Ripco. Inc.
P.O. Box 9366 South Charleston, West Virginia Rus: Engineering Co=pany P.O. Box 587 Oak ?idge, Tennessee 37830 Samson Steel Tabricators and Machine. Inc.
P.O. Box 126 Can to n, Ohio 44701 Sauer. Inc.
Mechanical Contrac: cts30-51s c Screet Pittsburgh, Pennsylvania 15201 Sharpsville Steel Fabricators. Inc.
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Sharpsfille, Pennsylvania 16150 I
Shee: 11ecal Products, Inc.
794 " orth 6th Street Newark, New Jersey 07107 Shell Che ical Company P.O. Box 235 Belpre. Chio 45714 Sistersville Tank Works (a Division of Superior Welding Cc=pany)
P.O. Box 200 Sis:ersville, Wes: Virginia 25175 Southeas: Paper Manufacturing Company Highway 199 Dablin, Georgia 31021 Standard Oil Co=pany Midland Building Cleveland. Chio 44115
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(7 Stauffer Chemical Company In 83-01 callipolis Ferry, West Virginia 25515 Janaury 26' 1983 Page 7 of 8 Stelle Corporation 1501 nichigan Street Sidney, Ohio 45365 s
i Sue:ers Hardware and Supply Company Buffalo and Ashe Streets i
Box 210 1
Johnson City Tennessee 37601 Taylor-Parker Company, Inc.
500 Industry Orive Ma=pton, Virginia 23361 Tennessee Eas t:an Co:pany Division of Eas t:an Kodak Company Kingsport, Tennessee 37662 Tilton Corporation 130 South Pine Lima, Ohio 45802 Timet 100 Titanium Way Toronto, Ohio 43964 TVA Chemical Stores Building Muscle Shoals Reservation Muscle Shoals, Alabaca 35660 T. V. A. Cu=berland Stes Plant Cucberland City. Tennessee 37050
..Cnion Ca:p Corporation P.O. Box 220 Cavet, Ohio 44622 Union Carbide Corporation P.O. B o y. 8361 South Charles ton, Wes t Virgtnia 25301 Virginia Electric and Power Company P.O. Box 26666 Rich =ond,. Virginia 23261
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Vulcan :'anufacturing Company (a Scbsidiary of Zurn Industries, Inc.) -
P.O. Box 46465 Cincinnati, Ohio '45246 Walker Stainless Equip =en t 6D1 State Street New Lisbon, Wisconsin 53950 Walter N. Yoder and Sons, Inc.
P.O. Box 1-337 Cu=berland, Maryland 21502 Weirton Steel (Division of National Steel Corporation)
- 'etrton, West Virginia 26062 Westvaco (Fine Paper: Division)
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Luke, Maryland 21340 W. H.
Kiefaber Ccapany P.O.
Bo:: 1:26 Dayton, ~ Chio 45401
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m 83-01 5: heeling-littsburgh steel corporation danaury 26, 1983
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P.O. 3n 116 Page 8 of 8 Pittsburgh, Pennsylvania 15230
- ices Pips and Supply Company 1728 John Street Cin c ir.na t i. Chio 45217 W.
J. Gill i
111 South Thecas Road Tallmadge. Ohio 44278 V. R. Crace and Cocpany Oavisen Chemical Division 477 5 Faddock Road Cincinnati, Ohio 45229 Youngstown Welding and Engineering Co=pany 3700 Oakwood Avenue Ycungs town. Chio 44509
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