ML20084G839

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Forwards Response to IE Bulletin 83-07, Apparently Fraudulent Products Sold by Ray Miller,Inc. Evaluations Indicate That Safety Impact,Due to Unauthorized Substitution of Ray Miller,Inc Matls,Negligible
ML20084G839
Person / Time
Site: Surry, North Anna, 05000000
Issue date: 04/05/1984
From: Stewart W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
440A, IEB-83-07, IEB-83-7, NUDOCS 8405070367
Download: ML20084G839 (60)


Text

VIMOTNIA ELucTHIC ann Pownn COMPANY HICIIMOND,VINGINTA 232 61 W.L.STnWANT xN.S. E717n.

April 5, 1984 Mr. James P. O'Reilly Serial No. 440A Regional Administrator N0/DWL:acm Region II Docket Nos. 50-280 U. S. Nuclear Regulatory Commission 50-281 101 Marietta Street, Suite 2900 50-338 Atlanta, Georgia 30303 50-339 License Nos. DPR-32

Dear Mr. O'Reilly:

DPR-37 NPF ^

NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY RESPONSE TO IE BULLETIN 83-07 APPARENTLY FRAUDULENT PRODUCTS SOLD BY RAY MILLER, INC.

In response to the initial NRC notification of apparently fraudulent Ray Miller, Inc. material in late 1982, Vepco has made a considerable effort to identify and locate any materials received from the Ray Miller organization.

Information on our initial effort was provided to you in our letter from Mr.

T. Justin Moore, Jr. to Mr. Richard C. DeYoung (NRC) dated February 9, 1983 (Serial No. 049).

Vepco has continued our efforts to identify, locate, and evaluate the fimpact S

of Ray Miller materials in our nuclear facilities.

IE Bulletin 83-07 Jdated July 22, 1983, provided additional information toward our review o4 this' concern and requested that reports be submitted detailing the resultgof our efforts.

Attachment I to this letter provides our response to IEB $Qy07 for the Surry Power Station.

Surry's response contains test results for*some Ray Miller, Inc. material which was available for testing. Attachment 2cprovides our IEB 83-07 response for the North Anna Power Station.

CA We firmly believe as a result of our evaluations that the impact on plant safety due to the unauthorized substitution of materials by Ray Miller, Inc.

is negligable.

We believe that our engineering, operations, and quality assurance programs continue to provide reasonable assurance that our nuclear facilities are designed, constructed, and operated to provide the highest degree of public safety.

The information contained in this response is accurate and true to the best of my knowledge.

If there are any questions or we can be of additional assistance in resolving the Ray Miller concern, please contact us.

Very truly yours, 8405070367 840405 4

PDR ADOCK 05000280 W

G PDR y',

g. Stewart l

cc: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555 hl

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SURRY POWER STATION RESPONSE TO IE BULLETIN 83-07 APPARENTLY FRAUDULENT PRODUCTS SOLD BY RAY MILLER, INC.

1

Background:

In late 1982, Surry Power Station personnel learned that Ray Miller was under indictment for selling fraudulent products, some of which may have been purchased by nuclear power plants.

Based on this information, a review was conducted of what turned out to be approximately 30 purchase orders that had been submitted to Ray Miller, Inc. for stock material.

All material identified by this preliminary review that was still in stock was removed from stock and placed in a non-issue status. The NRC was informed of these actions and a meeting was held in Bethesda, Md. to discuss the generic issues.

Based on the meeting, it was decided to conduct random sampling of the material which had been placed in non-issue status. This testing revealed no failures, however the material remained in non-issue status.

Results of this testing are provided in the response.

Surry decided to eventually dispose of the material rather than re-catagorizing or justifying its use.

In July 1983, NRC issued IE Bulletin 83-07 which provided information regarding specific purchase orders for which materials were apparently substituted.

Additional reviews of non-stock item purchase order were conducted. As a result a total of over 320 additional purchase orders were identified as being placed with Ray Miller, Inc.

Licensees were requested to determine where suspect material had been installed in plants, evaluate its safety significance, and tag or dispose of the suspect material not yet installed.

Licensees were also requested to examine and test materials from other Ray Hiller offices which were not included in the NRC identified list of apparently fraudulent materials. Vepco's responses to IEB 83-07 inquiries are as follows:

Paga 2 Item 1: Based on a review of the lists of Ray Miller, Inc. customers who received apparently fraudulent materials (IEB 83-07, Attachments 1 and 2),

and pertine:tt information obtained from any of these companies either directly or indirectly:

i (cf Identify those compantes on the lists that supplied materials or services to your facility (include subcontractors as well as major contractors)

Response

As a result of a review of the available purchase order informatlon, ten companies (in addition to Ray Millet-) listed in the attachments to IEB 83-07 were identified as potential suppliers of Ray - Miller materials to Vepco.

Of these ten suppliers, two were identified as end users of the apparently fraudulent material by supplements 1 and 2 of IEB 83-07.

Three companies provided the suspect material to other companies or suppliers, none of which were subsequent suppliers to Vepco.

Two companies identified as potential suppliers ~ did not provide any safety-related materials to the Surry facility.

Seven purchase orders (PO's) for safety-related materials were re'ceived

- from the three remaining. companies.-

These PO's were reviewed; and

- were either small diameter tubing or components = not suspect' 'as L Ray.

Miller fraudulent materials.

Page 3 Note: The above information was obtained from the best available cross-reference source of supplier names.

i The source was a computer listing containing safety-related PO's over a time period of 1974 through 1980.

The list contained over 1500 PO's and is believed to l

be reasonably complete.

A review of all available P0's against the IEB Attachment 1 & 2 lists was deemed impractical on the basis of the large volume e

of effort required and the fact that rarely did a P0 identify previous suppliers.

Information on previous auppliers would have been necessary to positively identify any material as coming through the Ray Miller organi?ation.

l Most material identified from our review was supplied directly by Ray Miller, Inc.

Where a third company was identified, it'. has ; been determined that the material supplied. was. either qualified, not

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a intended for use in a safety-related system, or of_such a_ dimension (e.g., 3/4" stainless steel. pipe plugs) that even complete failure in service would not be a serious challenge to plant integrity.

Item 1: '(b) Determine whether any of the fraudulent Ray Miller, Inc.

materials were provided or used at your facility.~.

Response

Attachments 1-and 2 of'IE Bulletin 83-071 1dentify. several ' PO's

- from Ray Miller as ' containing apparently fraudulent - materials.

Surry Power Station has records.of' receipts.of the'following:

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Paga 4 Purchase Order Description Remarks e

i 60122 Stainless steel piping All material was and fittings for Liquid received and apparently Waste Radiation issued as none was in Monitoring System stock at time of investigation upon initial notification in 1982.

75243 Small diameter (less All material was than 1"0 stainless steel received and apparently tubing) issued as none was in stock at time of investigation upon initial notification in I

1982.

j 21980 Small diameter (less 12 1/4" 3000# pipe plugs than 1") stainless steel were ordered, but 150#

j pipe plugs plugs were provided along with fraudulent documentation. One plug was located, tested at.

4500#, and did not fail.

All other material was received and apparently issued as none was in stock at time of-investigation upon initial notification in 1982.

Purchase Orders numbered 68471, 59818, and 75819 were not ' located.

All suspect material from these PO's was small diameter tubing where welded for seamless material was'sucr.txtuted.

Our review provided in Item la above provides reasonable assurance that little, if _ any, fraudulent. material found its way to Surry indirectly from Ray Miller.

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Item 1:

(c) Determine whether any of the apparently fraudulent material supplied to you was installed in safety-related systems at-your facility, or is still in stock.

Response

4 Vepco was unable to determine if apparently fraudulent materials were used in Safety-Related systems due to method._used at time of receipt 9

of items with regard to documenting where issued ' item was used.

However, the intended purpose for which the material was procured or-its small dimensions would pose' little threat to system integrity..

even in the event of complete failure.

Any item supplied by Ray l

Miller, Inc. which was in stock at the time of. the NRC's original l

notification in late 1982 was removed from stock and placed'in th'e

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4 reject area of the warehouse.

These items will not.be used at this-station and are being disposed of.

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Item 1:

(d) If other Ray Miller, Inc.. materials not listed in.

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Attachments 1 and.2 have : been identified ' by your own-

. initiative, determine whether any was installed int safety-related systems at your facility, or 1s - still in stock.

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Response

As indicated in the Background section of this response, a review of-non-stock PO's identified approximatly 320 additional PO's placed with Ray Miller.

Of these, only about 50 were in the time frame identified in IEB 83-07 and, in general, the purchased material was small diameter tubing or pipe. We are unable to determine if any of these materials were used in a Safety-Related system due to method used at time of receipt of items with regard to ~ documenting where issued item was used. None of this material is still in stock.

Item 2: For Ray Miller, Inc. materials, both the NRC-identified apparently fraudulent materials (listed in Attachments 1 and 2), and other materials identified by your own initiative, that are. installed in safety-related systems of your facility:

(a) Evaluate the safety significance of the presence of these materials assuming the fraud is as identified.in the-attachments of assuming material failure.

Response

Vepco was unable to make an adequate evaluation with -regard to the; safety significance of material list'ed ~because of lack of adequate documentation of specific locations of. suspect material.'.However,'

't Page 7 since any pipe, fittings, tubing or flanges installed in safety-related systems are adequately tested to conditions beyond their intended operating conditions prior to use, it is believed that any suspect Ray Miller material has and will continue to maintain system integrity and is acceptable for use.

Item 2:

(b) Determine the disposition of the installed material:

e.g.,

use as is, remove and replace, etc.

Response

Due to the inability to positively identify the location of Ray Miller material, any Ray Miller material in place in safety-related system will be used as is.

Our response to Item 2a provides adequate justification for this position.

Item 3: For all material from Ray Miller, Inc. still in stock. - whether identified by Item 1 or previously identified by your own initiative:

(a) Segregate into two groups:

(1) material included in the.

purchase orders listed in the fraudulent data file, and (2) all other material supplied by Ray, Miller, Inc.. regardless of the branch office that supplied the material.

(b) For-thematerdalincludedin;thefraudulent-datafile:

(1) Discard the material, or-.

~(2) Tag l or - otherwise ' mark the materials for use only in systems not important to safety.

(c) For material supplied by Ray Miller that is not included in

.the fraudulent data-file, do one of the following:

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Page 8 (1) Discard the material (2) Tag or otherwise mark the materials for use only in systems not important to safety, or (3') Subdivide material into groups of identical items and

' examine _and test material in each group _in accordance with either Item (1) or (ii), below.

3 (i) Perform sufficient comprehensive examinations and tests to qualify each group of material for use in systems important to safety.

If there are less than 10 identical items in the group, each item should be examined.

If there are 10 or more identical items, a statistical sampling plan may be-used to demonstrate with 90% of the material conforms to the purchase specifications.

Groups of material found ~ acceptable may J be used as desired.

(ii) Perform comprehensive examinations and tests of a limited sample of each group of identical items.

The minimum sample size 'is to be two _ items, or-10% of - the items in _ the group.whichever is greater.

Examination ~ and test of this limited 1

j sample does not provide a high degree of assurance that ~ the - entire group satisfies the procurement specifications ~. The-ERC will' compile' the results of all the data received, determine 1

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l the statistical significance of the results, and advise industry of the overall results and conclusions.

Therefore, a utility should not use the material in systems important to safety until the NRC's evaluation is complete.

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Response

Ali it'entified Ray Miller material not in use was segregated from

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stock.

Although there is no intention of using any of this segregated material in safety-related systems in. the' future, representative examinations and tests were performed.

The results are provided in the following pages of this report.-

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5176L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION:

ASTM A183, F304 MATERIAL:

3/8' Dia. Pipe Plug, 304 CRES NNS LAB. NUMBER: 809-W RESULTS OF TEST:

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Chemical Analysis SPECIFICATION: ASTM A182, F304 MATERIAL:

2" Dia. 90* Elbow, 304 CRES NNS IAB. NUMBER:

417-W RESULTS OF TEST:

Sample Carbon Chrome Manganese Nickel Silicon Phosphorus Sulphur

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Nterial Examination and Test Results Description of Material Examined & Tested Pipe 2 1/2" Sch 40 Key Procurement Specifications ASTM A312 TP 30k Date of Purchase 01-08-81 Ray Miller Branch Of fice That Supplied the Material S. Charleston, W. Va 20 feet Quantity of Material in Stock Quantity of Material Examined and Tested 1 root Tests & Examinations Perfortned See Attached Test ResultsSee Attached Stock Item 3885h92

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CUSTOMER: VEPCO-Surry CHARGE NUMBER:

5176L-135 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A312 MATERIAL:

2 1/2" Dia. Pipe, 304 CRES NNS IAB. NUMBER: 418-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Silicon Phosphorus Sulphur

.06 18.96 1.48 9.70

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Material Examination and Test Results Description of Material Examined & Tested Tubing,1/2" Seamless Key Procurement Specifications ASTM A269 Date of Purchase 10-09 8o Ray Miller Branch Office That Supplied the Material S. charleston, W. Va Quantity of Material in Stock 168 feet Quantity of Material Examined and Tested i root Tests & Examinations Performed See Attached Test Results See Attached Stock Item 3655kTo m

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CUSTOMER: VEPCO-Sur ry CHARGE NUMBER: 5176L-135 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A269, 304 MATERIAL:

1/2" Dia. Tube, 304 CRES NNS IAB. NUMBER:

419-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Silicon Phosphorus Sulphur

.02 19.07 1.89 9.16

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CUSTOMER: VEPCO-Surry CHARGE NUMBER: 5176L-135 TEST REQUIRED:

Chemical Analysis i

SPECIFICATION: ASTM A182, F316 MATERIAL:

2" Dia. Tees, 316 CRES NNS 1AB. NUMBER: 420-W RESULTS OF TEST:

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Chemical Analysis SPECIFICATION: ASTM A182, F316 MATERIAL:

2" Couplings, 316 CRES NNS 1AB. NUMBER: 421-W RESULTS OF TEST:

Semple Carbon Chrome Manganese Nickel Moly Silicon Phosphorus Sulphur

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Nterial Examination and Test Results Description of Material Examined & Tested Pipe 1 1/2" Sch 160 Key Procurement Specifications ASTM A312-TP304 Date of Purchase 06-oh-80

s. charleston, W. Va Ray Miller Branch Office That Supplied the Material Quantity of Material in Stock 63 feet Quantity of Material Examined and Tested i root Tests & Examinations Perfomed see attached Test Results See attached Stock item 3885509 d

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CUSTOMER: VEPCO-Sur ry CHARGE NUMBER: 5176L-135 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A312, TP 304 MATERIAL:

1 1/2" Dia. Tube, 304 CRES NNS LAB. NUMBER:

422-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Silicon Phosphorus Sulphur

.07 19.68 1.99 10.04

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DESTRUCTIVE TESTING REPORT REQUESTED BY: Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER:

5176L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A312, TP304 MATERIAL:

3/4" Dia. Sch. 40 Pipe NNS IAB. NUMBER: 795-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Silicon Phos phorus Sulphur

.06 19.07 1.82 9.60

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Tests & Examinations Performed See Attached Test Results See Attached Stock Item 3850153 e

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m Alenneco Company Newport News, Virginia 23607 (804) 330-7000 DESTRUCTIVE TESTING REPORT REQUESTED BY:

Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER:

5176L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A182, F316 MATERIAL:

1 1/4" Dia. Blind Flange, 316 CRES NNS 1AB. NUMBER:

810-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Moly Silicon Phosphorus Sulphur

.06 17.43 1.93 12.73 2.06

.22

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O 2/4/83 te, V J. H. Arthur, 'Jr.

Date Section Manager, Laboratory Services DISTRIBUTION:

3 Copies / Newport News Industrial Corp.

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Chemical Analysis s

SPECIFICATION: ASTM A182, F316 MATERIAL:

3/4' Dia. Pipe Tee NNS IAB. NUMBER: 802-W RESULTS OF TEST:

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.08 17.09 1.65 12.63 2.45

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Tests & Examinations Performed See Attached Test Results See Attached Stock Item 3856576 e

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Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER: 5176L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A312, F316, 316 CRES MATERIAL:

1" x 2" Sch. 80 Pipe Nipple, 316 CRES NNS IAB. NUMBER: 799-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Moly Silicon Phosphorus Sulphur

.04 16.42 1.71 12.00 2.43

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5176L-139 TEST REQUIRED: Chemical Analysis SPECIFICATION: ASTM A312, TP316 MATERIAL:

1" Dia. Sch. 60 Pipe, CRES NNS 1AB. NUMBER: 796-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Moly Silicon Phosphorus Sulphur 9

.06 16.48 1.82 12.23 2.05

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Quantity of Material Examined and Tested 1 Tests & Examinatioits Perforned See Attached Test Results See Attached Stock Item 3865T10 e

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CUSTOMER: VEPCO-Surry CHARGE NUMBER: 517 6L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A182, F304 MATERIAL:

1" Pipe Plug, 304 CRES NNS 1AB. NUMBER:

804-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Silicon Phosphorus Sulphur

.01 18.37 1.59 8.66

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Quantity of Material in Stock 11 Quantity of Material Examined and Tested 1 Tests & Examinations Performed See Attached Test Results See Attached Stock item 387046h e

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CUSTOMER: VEPCO-Surry CHARGE NUMBER: 517 6L-139 TEST REQUIRED: Chemical Analysis SPECIFICATION: ASTM A182, F316 MATERIAL:

1/4" Dia. Pipe Tee, 316 CRES NNS IAB. NUMBER:

P08-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Moly Silicon Phosphorus Sulphur

.04 17.90 1.43 12.77 2.00

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Key Procurement Specifications 316 S/S Date of Purchase 08-22-79 Ray Miller Branch Office That Supplied the Material S. Charleston, W. Va Quantity of Material in Stock 11 Quantity of Material Examined and Tested 1

Tests & Examinations Performed See Attached l

Test Results See Attached Stock item 3805600 I

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REQUESTED BY: Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER: 5176L-139 TEST REQUIRED:

Chemibal Analysis SPECIFICATION: ASTM A132, F316 MATERIAL:

1/4" x 3/4" Pipe Bushing, 316 CRES NNS IAB. NUMBER: 801-W RESULTS OF TEST:

Carbon Chrome danganese Nickel Moly Silicon Phosphorus Sulphur

.07 16.67 1.70 10.24 2.01

.52

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.022 Conforms to specification.

1 2/4/83

(/J. H. Arthur, J#.

Date Section Manager, Laboratory Services DISTRIBUTION:

3 Copies / Newport News Industrial Corp.

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Tests & Examinations Perfonned See Attached Test Results See Attached Stock Item 3806115 e

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Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER:

5176L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A182, F304 MATERIAL:

1 1/4" x l' Reducer, 304 CRES NNS IAB. NUMBER: 798-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Silicon Phosphorus Sulphur

.03 18.71

.80 9.33

.47

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.012 Conforms to specification.

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3 Copies / Newport News Industrial Corp.

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hierial Examinatien and Test Results Description of Material Examined & Tested Reduced 11/2 to 11/h Key Procurement Specifications ASTM A182 - F30h Date of Purchase 05-23-79 Ray Miller Branch Office That Supplied the hteria1. Charleston, W. Va S

Quantity of hterial in Stock 12 Quantity of hterial Examined and Tested 1

Tests & Examinations Perfonned See Attached Test Results See Attached Stock Item 3806135 4

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DESTRUCTIVE TESTING REPORT REQUESTED BY:

Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER: 5176L-139 TEST REQUIRED: Chemical Analysis SPECIFICATION: ASTM A182, F304 MATERIAL:

1 1/2" x 1 1/4" Reducer, 304 CRES NNS IAB. NUMBER:

807-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Silicon Phosphorus Sulphur

.01 19.42 1.99 10.68

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.003 Conforms to specification.

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Date Section Manager, Laboratory Services DISTRIBUTION:

3 Copies / Newport News Indu: trial Corp.

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I Material Examination and Test Results Description of Material Examined & Tested coupling 3/4 pipe Key Procurement Specifications ASTM A182-F316 Date of Purchase 05-23-79 Ray Miller Branch Office That Supplied the Material S. Charleston, W. Va Quantity of Material in Stock 2 Quantity of Material Examined and Tested 1

Tests & Examinations Perforined See Attached Test Results See Attached Stock Item 38257h3 9

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REQUESTED BY: Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER:

5176L-139 TEST REQUIRED: Chemical Analysis SPECIFICATION: ASTM A182, F316 MATERIAL:

3/4" Dia. Pipe Coupling, 316 CRES NNS IAB. NUMBER: 803-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Moly Silicon Phosphorus Sulphur

.05 16.70 1.51 10.05 2.09

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Material Examination and Test Results Description of Material Examined & Tested Coupling, Pipe 1" Key Procurement Specifications ASTM A182-F316 Date of Purchase 03-09-79 Ray Miller tranch Office That Supplied the Material S. charleston, W. va.

Quantity of Material in Stock 6 Quantity of Material Examined and Tested 1

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DESTRUCTIVE TESTING REPCRT REQUESTED BY: Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER: 5176L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A182, F316 MATERIAL:

1" Dia. Pipe Coupling, 316 CRES NNS 1AB. NUMBER: 800-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Moly Silicon Phosphorus Sulphur

.04 16.39 1.36 10.12 2.09

.52

.029

.022 Conforms to specification.

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3 Copies / Newport News Industrial Corp.

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l Material Examination and Test Results Elbov 316 Description of Material Examined & Tested 3/4 Diameter 45 Key Procurement Specifications F 182 - F 316 Date of Purchase 03-09-79

s. charleston, W. Va Ray Miller Branch Office That Supplied the Material Quantity of Material in Stock lo Quantity of Material Examined and Tested 1

see attached Tests & Examinations Perfonned I

Test Results see Attached l

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Alenneco Company Newport News, Verg.nia 23607 (804) 380-2000 f'

DESTRUCTIVE TESTING REPORT REQUESTED BY:

Miriam Peternell, Newport News Industrial Corp.

CUSTOMER: VEPCO-Surry CHARGE NUMBER: 5176L-139 TEST REQUIRED:

Chemical Analysis SPECIFICATION: ASTM A182, F316 MATERIAL:

3/4"Dia. 45' Elbow, 316 CRES NNS 1Ab. NUMBER:

797-W RESULTS OF TEST:

Carbon Chrome Manganese Nickel Moly Silicon Phospho rus Sulphur

.07 16.98 1.66 12.62 2.45

.48

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.014 Conforms to specification.

O 2/7/83 4/J. H. Arthur, (tr.

Date Section Manager, Laboratory Services DISTRIBUTION:

3 Copies / Newport News Industrial Corp.

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4 ATTACHMENT 2 NORTH ANNA POWER STATION

NORTH ANNA POWER STATION RESPONSE TO IE BULLETIN 83-07 APPARENTLY FRAUDULENT PRODUCTS SOLD BY RAY MILLER, INC.

Background:

In late 1982, North Anna Power Station personnel learned that Ray Miller was under indictment for selling fraudulent products, some of which may i

have been purchased by nuclear power plants.

Based on this information, a review was conducted of what turned out to be 42 purchase orders that had been submitted to Ray Miller, Inc. for construction material. An additional 4 P0's were identified from a supplier who had received material from Ray Miller.

A-review of this suspect material was performed.

Information obtaiaed from this review is contained in the following responses.

In July 1983, NRC issued IE Bulletin 83-07 which provided information regarding specific purchase orders for which materials were apparently substituted.

Licensees were requested to determine where suspect material had been installed in plants, evaluate its j

safety significance, and tag or dispose of the suspect material not yet installed.

Licensees were also requcated to examine and test materials from other Ray Miller offices which were not included in the NRC identified list of apparently fraudulent materials. Vepco's responses to IEB 83-07 inquiries are as follows:

l r

Item 1:

Based on a review of the lists of Ray Miller, Inc. customers who received apparently fraudulent materials (IEB 07, Attachments 1 i

and 2), and pertinent information obtained from any of these companies either directly or indirectly:

I (a)

Identify those companies on the lists that supplied materials or services to your facility (include subcontractors as well as major contractors)

Page 2

Response

As a result of a review of the available purchase order'information, ten companies (in addition to Ray Miller) listed in the attachments to IEB 83-07 were identified as potential suppliers of. Ray Miller materials to Vepco.

Of these ten suppliers, two were identified as end users of the apparently fraudulent material by supplements 1 and 2 of IEB 83-07.

Three companies provided the suspect material to other companies or suppliers, none of which were subsequent suppliers to Vepco.

Two companies identified as potential suppliers did not provide any safety-related materials to the North Anna facility.

Ten purchase orders (PO's) for' safety-related materials were received from the three remaining companies.

These PO's were reviewed and j

were either components not suspect as Ray' Miller fraudulent materials I

)

or verification was made that the materials were shipped directly 1

from the manufacturer and were never in Ray Miller, Inc. possession.

)

l Note: The above information was obtained from the best available cross-reference source of supplier names.

1l The source was a computer listing containing safety-related PO's over'a time period of 1974 through 1980.

4 The list contained over 1500 PO's and-is believed to be reasonably complete. ' A review of all ' availab' e l

P0's against ' t.he IEB Attachment l'& 2. ' lists was deemed impractical on the basis of the large volume.

of effort required and the fact that rarely did a PO

Page 3 identify previous suppliers.

Informat' ion on previous _-

suppliers would have been necessary to positively identify any material as coming: through the Ray Miller organization.

Most material identified from our review was supplied directly by Ray Miller, Inc. Where a third company was identified, it was determined that the material supplied was not material identified as suspect since it typically was a component part (e.g. valve) and not pipe, tubing or fitting / flange material.

Item 1:

(b) Determine whether any of the fraudulent Ray Miller, Inc.

materials were provided or used at your. facility.

Response

Attachments 1 and 2 of IE Bulletin 07 identify several. PO's from Ray Miller as containing apparently fraudulent mat'erials..

North Anna Power Station records indicate no. receipts of.

apparently fraudulent Ray Miller. material.

- q Our -review. provided in Item la above provides reasonabl'e-

-assurance-that little, if any,' fraudulent material found its way-to North Anna indirectly from Ray; Miller.

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Paga 4 Item 1:

(c) Determine whether any of the apparently fraudulent material supplied to you was installed in safety-related systems at your facility, or is still in stock.

Response

No apparently fraudulent material has been identified as being received at the Noren Anna facility.

Item 1:

(d)

If other Ray Miller, Inc.

materials not listed in Attachments 1 and 2 have been identified by your own j

initiative, determine whether any was installed in safety-related systems at your facility, or is still in stock.

Response

1 As indicated in the Background section of this response, a review of 1

PO's identified approximatly 42 PO's placed with Ray Hiller.

These t

'i PO's contained 356 line items placed with Ray Miller, Inc. The timo i

span of these purchases was 1/26/71 to 6/24/74.

Of the 42 PO's placed with Ray Miller only 12 indicated possible safety-related applications. Of the 12 PO's identified as possibly safety-related, one was shipped directly from the manufacturer, and one was used for the North Anna 3 lower containment liner.

The remaining 10 PO's (containing 20 line items) contained 6 tubing line items, and 14 pipe or fitting line items.

Objective evidence is available that the 14 pipe or fitting line items were not used in safety-related systems. The use of the 6 tubing line items is specified as follows.

Page.5 l.

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3 - Level Control Pipe - 1/2", Type 304 A269 i

i 1 - Containment liner bottom - 3/8", Type 316 i

1 - Containment liner - 1/2", Type 316 i

1 - unidentified use - 5/8", Type 316 A269 l

i An evaluation was performed to access the safety significance of i

having Ray Miller material in these.5 identified locations assuming i

that substitutions had been made of the specified tubing material.

i It was concluded that even suspect material would perform.its j

1 j

intende? function since the quality of potentially substituted tubing

[

would have been adequate for the actual applications, i

i i

Item 2: For Ray Miller, Inc. materials, both the NRC-identified apparently fraudulent materials (listed in Attachments 1 and 2), and other j

materials identified by your own initiative, that are installed in safety-related systems of your facility:

[

l (a) Evaluate the safety significance of the presence of these i

materials assuming the fraud is as identified in the j

attachments of assuming material failure.

i

Response

I

)

This question is answered in part in Item Id.

However, since any

)

pipe, fittings, tubing or flanges installed in safety-related l

systems are adequately tested to conditions beyond their intended operating conditions prior to use, it is believed that any suspect Ray Miller material, which may have been installed, has and will l

continue to maintain system integrity and is acceptable for use.

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}

Page 6 s

Item 2:

(b) Determine the disposition of the installed material:

e.g.,

use as is, remove and replace, etc.

Response

Based on the dete rmination of safety significance provided in Item Id. any installed Ray Miller material will be used as is.

Item 3:

For all material from Ray Miller, Inc. still in stock, whether identified by Item I or previously identified by your own initiative:

(a) Segregate into two groups:

(1) material included in the purchase orders listed in the fraudulent data file, and (2) all other material supplied by Ray Miller, Inc., regardless of the branch office that supplied the material.

(b)

For the material included in the fraudulent data file:

(1) Discard the material, or (2) Tag or otherwise mark the materials for use only in systems not important to safety.

(c)

For material supplied by Ray Miller that is not included in the fraudulent data file, do one of the following:

(1) Discard the material (2) Tag or otherwise mark the materials for use only in systems not important to safety, or (3) Subdivide material into groups of identical items and

~

examine and test material in each group'in accordance with either Item (i) or (ii), below.

Paga 7 (i) Perform sufficient comprehensive examinations and tests to qualify each group of material for use in systems important to safety.

If there are less than 10 identical items in the group, each item should be examined.

If there are 10 or more identical items, a statistical sampling plan may be used to demonstrate with 90% of the material conforms to the purchase specifications.

Groups of material found acceptable may be used as desired.

(ii) Perform comprehensive examinations and tests of a limited sample of each group of identical items.

The minimum sample size is to be two items, or 10% of the items in the group whichever is greater.

Examination and test of this limited sample does not provide a

high degree of assurance that the entire group satisfies the procurement specifications. The NRC will compile the results of all the data received, determine the statistical significance of the results, and advise industry of the overall results and conclusions. Therefore, a utility should not use the material in systems important to safety until the NRC's evaluation is complete.

Response

No Ray Miller material was available for testing.