ML20087L131

Responds to IE Bulletin 83-07, Apparently Fraudulent Products Sold by Ray Miller,Inc. Nuclear Grade Matls Not Purchased Directly from Ray Miller,Inc.Review of Matls Supplied by Subvendors Continuing

ML20087L131
Person / Time
Site:	Cook
Issue date:	03/22/1984
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
AEP:NRC:0779A, AEP:NRC:779A, IEB-83-07, IEB-83-7, NUDOCS 8403270047
Download: ML20087L131 (10)

Text

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e INDIANA & MICHIGAN ELECTRIC COMPANY

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P.O. BOX 16631 COLUMBUS, OHIO 43216 March 22, 1984 AEP:NRC:0779A Donald C. Cook Nuclear Plant Unit Nos. I and 2 Docket Nos. 50-315 and 50-316-License Nos. DPR-58 and DPR-74 NRC IR BULIJtTIN No. 83-07 APPARENTLY FRAUDUIENT PRODUCTS SOLD BY RAY MILIER, INC.

l Mr. Richard C. DeYoung, Director Office of Inspection ir Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

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Dear Mr. DeYoung:

This letter is in response'to the NBC IE Bulletin No. 83-07 entitled, "Apparently Fraudulent Products ' sold by Ray Miller, Inc.," dated July 22, 1983. This letter has been addressed to you as directed by Mr. D. Boyd of

. the NRC Region III staff on March 21, 1984. This direction was given to our staff in response to our request for an additional four months to complete our review of the subvendors. The continuing review is to determine if che subvendors supplied any materials which were indirectly sold by Ray Miller, Inc. to Donald C. Cook Nuclear Plant.

Mr. Boyd indicated that based on his discussion with-Ms. M. Wegner of your staff the request was granted but we should document the request in this letter.

Our purchasing records have been examined to determine if any nuclear grade materials have been purchased directly from Ray Miller, Inc. during construction or operation of the Donald C. Cock Nuclear Plant, Units 1 and 2 during the period 1975 to 1979. As a result of this review it was found that we have not purchased any nuclear grade materials directly from Ray Miller, Inc.

Attachments 1 and 2 of the subject Bulletin were reviewed to 13entify possible purchase of the fraudulent products through indirect suppliers

.and/or subcontractors during the time period of 1975 through 1979.

As an. initial step we have. compared our qualified suppliers list (glL) for Cook Plant safety related materials and equipment to those lists in Attachments 1 and 2 of the subject bulletin. The result of this review indicates that there are relatively few suppliers -listed on both lists i.e.,

the NRC IE Bulletin list and the QSL for Cook Plant. This does not-necessarily mean that the suppliers that appear in both lists have furnished Ray M!11er, Inc. materials to the Cook Plant.

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Mr. Rich 0rd DsYctag AEP NBC 0779A Wo.are presently. in the process of contacting these " matched" suppliers (twelve suppliers as noted in response to Item 1.a.) to determine if they did furnish any safety related asterials to the Cook Nuclear Plant that g

- originated with Ray Miller, Inc.

The following are -Indiana-& Michigan Electric Company's responses to items -1, 2-and -3~ of the NRC Bulletin-83-07. The item numbers of the responses correspond to the same numbers as those in the Bulletin.

Response to Item _Np _1_

a)-

The following companies listed in Attachments I and 2 of the Bulletin have been identified as suppliers of safety related materials to the Cook Plant.

1. - Chicago Tube & Iron 2.

Irwin Steel Fabricators

3. - Worthington Pump Corporation 4.

Richmond Engineering Company [kEC0]

5.

Mideo Pipe & Tube company 6.

Westinghouse Electric Company 7.

General Electric Company d

8.. Ingersoll-Rand Corporation 9.

Dresser Industries

10. - Union Carbide Corporation

11. Could Inc.

12. JAB 0 Supply Company-b)

~In addition, we are still in the process of reviewing our records to determine all of the unterials the various vendors have supplied, and

.following this we will ask our suppliers to review their records to determine whether any material was supplied by Ray Miller, Inc. during 1975-1979.-

One definite case where materials were supplied by Ray Miller, Inc. has been identified. The materials were used in the f abrication of components of the Pressuriser Relief Tank (FRT) for Unit No.-2 of the Cook Plant, which is a non-nuclear safety cosponent. In this case the PRT was supplied. to us by the Westinghouse Electric Corporation which in turn subcontracte' the fabrication of the tanks and components to RECO Industries, Inc. Ciormerly Richmond Engineering Company, Inc.)

RECO purchased the materials from Ray Miller, Inc. during the period from 1969 through 1973, which -is outside the period of concern.

c)

We have not identified-any safety related systems in which apparently

-fraudulent materials supplied by Ray Millar, Inc. have been installed.

However our review is'still in progress. After the completion of our review, if we identify, any materials that have been received from Ray Miller, Inc. we.will promptly inform your office.

d)

'No other type of materials from Ray Miller, Inc. not listed in Attachments 1 and 2 of the Bulletin have been identified. Bovever,.

once the review noted in item c) above is completed, we will inform your office as necessary.

r Mr. Ricbcrd D1Yerug AEP:NRC:0779A Response to Item 2 a)

As noted in response to item 1.b above only one item (i.e., Unit No. 2 PRT) has been identified which contains materials from Ray Miller, Inc.

Though the time period in which the PRT was procured is not cited as a period of concern in the subject Bulletin, Westinghouse performed a safety evaluation relative to the items identified for the-PRT. The evaluation concluded that the PRT is a non-nuclear safety component and that the introduction of possible nonconforming material in components of the PRT does not result-in any _ change to the plant Technical l

Specifications, does not affect the safety analyses of the plant and does not -introduce an unreviewed safety question. The Westinghouse letter No. AEP-83-592 dated June 23, 1983 which contabas the safety evaluation is enclosed as Attachnent No. I to this letter.

b)

Based on the safety evaluation provided by the Westinghouse Electric Corporation, we plan to continue the use of the Pressuriser Relief Tank in the as is condition without any modifications or replacement.

Response to Item No. 3 As of this time we have not identified any safety related materials in our stock as material procured directly or indirectly from Ray Miller, Inc.

' However, after the completion of the review, if any fraudulent materials are r

identified we will provide the necessary evaluation as required by Item No. 3.

We are continuing our ef forts to contact the twelve companies who were listed in our purchasing' records and are listed in' Attachments 1 and 2 of the Bulletin. ;If any additional information is received which identifies that the materials procured from these companies were sold by Ray Miller, Inc., we will notify your office promptly. We anticipate that we will receive the responses from various supplier companies in the near future so that we can submit our final response by the end of July 1984.

Very truly yours, s

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exich Vice President tr MPA/cm cc: John E. Dolan W. ' C. Smith, Jr. - Bridgman R. C. Callen G. Charnof f J. G. Keppler, Regional Administrator, NBC, Region III E. R. Swanson, NRC Resident Inspector - Bridgman D. Boyd, NRC, Region III M. Wegner, NRC, Washington, D.C.

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STATE OF OHIO COUNTY OF FRAKLIN M. P. Alexich, being duly cworn, deposes and says that he is the

. Vice President of -Licensee, Indiana & Michigan Electric Company, that he has read the foregoing response to the 'NRC IE Bulletin No. 83-07, "Apparently Fraudulent Products Sold by Ray Miller, Inc.,"

dated July 22, 1983 and knows the contents thereof; and that said contents are true to the best:of his knowledge and belief.

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~ Mifton P. A[exich d

Subscribed and sworn to before me the 23n,l day of MOMo,1984.

M AM% tMcd Iththff (potary Publie)

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i ATTACHMENT NO. 1 TO AEP:NRC:0779A n

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Attachment No. 1 4-IND.'4 MICH. ELECTRIC CO.

AEP:NRC:0779A 3 rP rid TP W H T P L

h JUL 11983 Westinghouse WaterReacto[.LWOL5U U l.b noci,s me Electric Corporailon Divisions DONALD C. COOK PLANT maammsim f

MANAGERIAL '

h 598 Pittsburgt Pemsylvania15230 June 23,.1983

/AEP83592 Mr. W. G. Smith, Plant Manager i

L U.- C. Cook Nuclear Plant Indiana and Michigan Power Company P. O. Box 458.

.Bridgman, Michigan 49106

Dear.Mr. Smith:

American Electric Power Service Corporation

.D. C. Cook Unit 2 RAY MILLER. INC.. SUPPLIED MATERIALS - PRESSURIZER RELIEF TANKS

.Reforences: 1) -NRC Information Notice No;-83-01-(attached)'

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2) NRC~Information Notice No. 83-01 Supplement 1

.3) RECO Industries,-Inc. letter to Westinghouse (attached)

RECO Industries, Inc. (formerly, Richmond Engineering Co... Inc.) has informed

i We'stinghouse, per Reference 3, attached, that Pressurizer Relief Tanks built L

by.them and supplied to Westinghouse for your. plant-contain material 'which

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was procured from Ray Miller, Inc..The referenced NRC documents-1 and 2 described certain fraudulent practices used by Ray Miller, Inc.-in supplying materials;to its. customers, and identified RECO Industries,'Inc. as one

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customer:who had'alledgedly been supplied non-conforming materials.

Westinghouse has performed-a-safety evaluation relative to the items

-identified for the. Pressurizer. Relief Tanks' and has concluded that the introduction of possibly non-conforming material as described into components of-the' Pressurizer Relief Tank does not result 1n any change of plant technical; specifications. Based on an evaluation performed, it has.been determined.that a failure of the Pressurizer Relief. Tank components listed

~~does.not affect any safety analyses performed for your plant, nor does it introduce any.unreviewed safety. questions.

sThe Pressurizer Relief Tank (PRT) is classified as Non-Nuclear Safety (NNS) and.does not perform any safety function, mitigate the consequences of an accident,;nor'is,it part of the RCS, pressure boundary.

7 (Part B of Reference 1, attached, describes:the a11 edged scheme to defraud as practiced by. Ray Miller,~Inc.. Part Bl. addresses the'a11 edged practice of passing foreign manufactured pipes and nipples as~ domestic-made products.

This. conce'rn apparently does not question the adequacy of the material, only its! source. -Parts'~B2. and 3. address the alledged practice of passing c--

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standard carbon content 304 and 316 stainless' steel as low carbon content.

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Attachment No. 1 AEP:NRC:0779A June 23, 1983 Page 2 As noted in reference 3, all items supplied were 304 stainless steel and thus are not as likely to be misrepresented as low carbon grades of stainless steel.

Part B4. addresses the passing of welded and drawn tubing as seamless tubing.

Reference 3 identifies the use of 3/4", 1-1/2",

2", 3" and 4" seamless pipe in the manufacture of some of the Pressurizer Relief Tanks.

Assuming this seamless pipe is the same as the seamless tubing identified in Part B4, it is possible that some and/or all this material could be welded and drawn. NOTE: This item is not applicable to your plant, since no parts using seamless pipe were provided by Ray Miller, Inc.

Even though the potential exists that the criginal ASME Code calculation for

.the pt-essure boundary components of the PRT may be invalidated, no nuclear safety concern exists since the Design Basis Accidents Analyses envelop any consequences which could originate from any failure of the Pressurizer Relief Tank.

Based on the information available to date, that is no nuclear safety concern exists, and the fact that in Reference 2 the NRC states they will be issuing a more complett list of purchase orders that alledgedly involve fradulent substitution of materials, Westinghouse recommends that any activity for your plant on this issue await the NRC issuing of the additional information. At that time you should review the situation and establish the most appropriate course of action.

If the need arises, Westinghouse will support you as requested.

Very truly yours,

// A. Tri ager p'

j perating lant Projects a

Central Region DG 307L Attachments cc:

M. P. Alexich J. Kern W G. E. Kubanesek W Li

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Attachment No. 1 AEP:NRC:0779A

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';I RECo lnoustries. Inc

!I Tm & Hosceral Stre.*tS 804/644-2611 a

Box 25189. Nnrnona. virgaa 22260 5189

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Te+ex 827 474 Tei,Cm 8M3 3561 April 1 A w e.

Westinghouse Electric Corporation Nuclear Energy Systems Post Office Box 355 Pittsburgh, Pennys1vania 15230 Attention:

Mr. Wayne Arendes Manager of Procurement

Subject:

Nuclear Procurement, Ray Miller, Inc.

Reference:

NRC Information Notice No. 83-01 Gentlemen:

The referenced NRC document described certain fraudulent practices by Ray Miller, Inc. in the sucol.y of mater ials to its customers. Ray Miller, Inc. was an anproved vendor to our company from 1969 through 1973.

RECO Industries, Inc. (formerly Richmond Engineering Co., Inc.) has researched nuclear contract documentation te determine if any items of material were supplied by Ray Miller. Inc. We have determined that the contract listed below has components supplied by Ray Miller, Inc.

Contract No.

546-CRI-84981 BN RECO Job No.

L11130, L11131, L14976, L15506, LI34 YJ Equipment:

Pressurizer Relief Tanks I have enclosed additional data on the items suoplied.

RECO has examined the material documentation for these items. We j

have no reason, otner than the referenced NRC document, to believe that these items are not as represented by the documentation. We encourage you to examine your documentatich packages for this ecuipment.

We feel the following considerations are significant to your evaluation of these materials:

1.

Some of the items sucplied by Ray Miller, Inc. are internal, nonpressure boundary parts.

m estTAL PLAft sAssesCArons atAf EXCMAasGEms sMt0Ctss vtSSELS & STORAGE Taasts se STEEL StassLESS STEEL Awussuu COpogm a LLovs

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Ai.tachment No. 1

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Westingh:use Electric Corp.

AEP:NRC:0779A April 1, 1983 Page 2 o

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2. - Items supplied are 304 stainless steel and are probably not as.

4 likely to be misrepresenteJ as higher grades of stainless.

If we,can provide additional infonnation, plasse contact us.

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Sincerely _yours, d \\. -

RECO Industries, Inc.

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Gr n A. Her in P.ET e President, porate neering GAH/mtw t'

United States NuE) ear Regulatory Connission, cc:

Region II 6

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Attachment No. 1 AEP:NRC:0779A 1

PRESSURIZER RELIEF TANK Westinghouse P.O.

1. 546-CRI-84981 BN RECO Job No.

L13843 Westinghouse Item:

AMPRCATPR-01 Westinghouse Drawing:

110'E 272 Sub 3 Shipped to:

Nuclear Engineering Division, AM. Electric Power Service, New York City (Export)

Date Shipped:

November 5, 1971 Description of material supplied by Ray Miller, Inc.

Westinghouse Ma rk No.

Service Description 25 Internal Pipe 12" Sch 40 90' E11 T-304, HT #951898 35 Temp Connection li" 150# RF WN Flange T-304, HT #HF629 36 Temp Connection 11" 150# RF Bld Fig T-304, HT #HF660 44 Internal Sparger 3" Sch 40 Tae T-304, HT #FL19880 45 Internal Sparger 3"x11" Sch 40 Reducer T-304, NT #SRAP 46 Internal Sparger ll" 2000# S.W. Tee T-304, HT #VR/RN 47 Internal Sparger 11" 2000# S.W. 90"E11 T-304, HT #XW

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