o [g3 K80 UNITED STATES-

y,( ~j NUCLEAR REGULATORY COMMISSIONj -^%g )

.p WASHINGTON,0. C. 20555,

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JUN 3 01923

MEMORA!iDUM FOR: Victor Stello,.Jr.Deputy Executive Director

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Regional Operations & Generic Requirements *

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FROM: Richard C. DeYoung, DirectorOffice of Inspection and Enforcement

SUBJECT: REQUEST FOR REVIEW OF PROPOSED IE BULLETIll AND LETTER TONON-LICEllSEES REGARDIllG RAY MILLER, INC. MATERIALS.

In accordance with the Commission-approved CRGR Charter, the Office ofInspection and Enforcement requests review of the proposed subject IE bulletinand letter to non-licensees (copies enclosed). Also enclosed are discussionsof the safety benefits and impacts to facilitate your review of the proposedbulletin and letter to non-licensees.

Attachments 1 and 2 to the bulletin are the lists of apparently fraudulentshipments obtained by the NRC review of available Ray Miller, Inc. records.They are quite bulky, so only your copy of the bulletin has the complete versionof these attachments. The copies sent to the cc list includes only a sample ofthe attachments.

We understand that pre-approved OMB clearance numbers have been granted forall bulletins. However, specific clearance nust be requested and obtained forthe letter to non-licensees. We are preparing the appropriate request and

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backup information.

The bulletin contains a request for action by power reactor licensees and theBarnwell facility to locate apparently fraudulent materials that they may havereceived, provide safety evaluations for installed apparently fraudulentmaterial, and test other Ray Miller material in stock. IE recommends approvalby CRGR.

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The letter contains a request for cooperation from customers of Ray Miller,Inc. to locate'apparently fraudulent materials which they purchased. Companiesthat were the end users of the material supplied by Ray Miller are asked to statethis. Ccmpanies that supplied the material to others are asked to assist theNRC in identifying nuclear facilities 'that were end users. IE recommends-

approval by CRGR.

CONTACTS: M. S. Wegner, IE492-24511

R. M. Young, IE49-29672

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8307110329 830700PDR REVOP l@tOCROR

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Victor Stello, Jr. -2- JUN 3 01983

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To this end, we would be happy to provide a briefing to the committee. We -'

suggest July 6,1983, the same day that CRGR will be reviewing the proposedIE bulletin concerning Tubeline Corporation.

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Please let us know if that date is satisfactory.'

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: Ri hard C. DeYoung, Direct r0 fice of Inspection and Enforcement

Enclosures:1. * Proposed IE Bulletin 83- :

Ray Miller, Inc.2. Proposed Letter to Non-licensees,

Subject: Ray Miller, Inc.3. CRGR Package for Bulletin and Letter

! cc: J. H. Sniezek, IET. A. Rehm, EDO!

J. M. Taylor, IEE. L. Jordan, IER. L. Baer, IE;

! W. S. Schwink, EDO (15 copies)R. E. Cunningham, NMSS,

Regional Administrators,

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Enclosure 1~ '

SSINS No: 6820/5340OMB No.:IEB 83-

UNITED STATESNUCLEAR REGULATORY COMMISSION

OFFICE OF It!SPECTION AND ENFORCEMENTWASHINGTON, D. C. 20555

June , 1983

IE BULLETIN N0, 83- : APPARENTLY FRAUDULENT PRODUCTS SOLD BY RAY MILLER, INE.

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Addressees:

For Action:

* All nuclear power reactor facilities and fuel facilities holding anoperating license (OL) or construction permit (CP).

For Information:

Other fuel cycle licensees and Category B, Priority I (processors anddistributors) material licensees.

Purpose:|

Power reactor facilities were informed in January 1983 by Information Notice83-01 that fraudulent products may have been sold to nuclear industry companiesby Ray Miller, Inc. An updated and comprehensive list of Ray Miller, Inc.customers for the years 1975-1979 was provided to power reactor licensees andto selected fuel cycle and Category B, Priority I material licensees in Supplement1 to IN 83-01 that was issued on April 15, 1983. Since information is nowavailable regarding specific purchase orders for which materials were apparentlysubstituted, licensees are requested to determine where suspect material hasbeen installed in plants, evaluate its safety significance, and test suspectmaterial not yet installed.

Discussion:

During February 1983, the NRC completed a detailed review of 29 file boxes ofRay Miller, Inc. records that were in the custody of the U.S. Attorney's Office

- in Charleston, West Virginia. These records related to orders filled by theCharleston, West Virginia branch office of Ray Miller, Inc., and covered the

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period 1975 through 1979. No other Ray Miller, Inc. records have beenidentified thus far.

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The data obtained from the records review are presented in Attachment 1, " FraudData Base Alpha Sequence Condense." These data are for apparently fraudulentitems only, and were selected on the basis of notations made on the Ray Miller,Inc. work sheets which indicated that unauthorized substitutions or modifications

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TEB 83-- *,

June ,1983,

Page 2 of

were made. The data are arranged alphabetically by buyer, and include deliverypoint, order number, order date, line number, material size, material type,fraud code, and comments.

The order number column provides the buyer's purchase order number when thiswas available. When it was not available, the Ray Miller, Inc. order number isprovided.

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The order date column lists the date of the buyer's purchase order when thiswas available. When it was not available, the Ray Miller, Inc. order date islisted.

The line number column provides the line number of the buyer's order for whichsubstitution or modification of material was apparently made.

The ' material size column provides a code entry for the size of the materialinvolved. For tubing, the size indicates the outside diameter. For pipe, thesize indicates the nominal size. For fittings and flanges, the size indicatesthe nominal pipe diameter for the material, however, there may be some incon-sistency in recording values in these cases. The codes are as follows:

Material size codes: 0 = 1" or less1 = greater than 1" and less than or equal to 2"2 = greater than 2" and less than or equal to 4"3 = greater than 4"

The material type column lists a code entry for the type of material involved.All items that are not piping or tubing are included in fittings and flanges.The codes are as follows:

Material type codes: PIPE = PipingTUBE = TubingFTFL = Fittings and Flanges

The fraud code column provides a code entry for the type of substitution ormodification that was apparently made. Dual or multiple entries for fraudcode indicate either substitutions of more than one type or that a determinationof which substitution was made could nct be established from the informationavailable.

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Fraud' codes: W = Welded for SeamlessC = Carbon Content (Std. grades of stainless steel for low.-

carbon or in some cases low carbon for Std.)F = Foreign-made for Dorestic-madeX = Forming or Machining performed-

P = Pressure Ratings substitutedT = All others, e.g. , 304 SS for 316 SS

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IEB 83-June ,1983* *

Page 3 of

Tne and/or column indicates whether multiple entries for the fraud code weremultiple substitutions (AND column) or determination of which substitutionwas made could not be established (OR column).

The comments column presents various notations that were found on the RayMiller, Inc. work sheets.

Attachment 2 " Fraud Data Base Condense Buyer / Delivery Point Differ" is a differentsorting of selected data contained in Attachment 1. In this case, the data are

arranged alphabetically by delivery point and only include data when the *

receiver (delivery point) differs from the buyer. This presentation is useful ,to identify materials that were delivered directly to a company that did notoriginate the purchase order.

The fraud data base file is not complete in all cases. Some of the informationwas not available from the Ray Miller, Inc. records. Items from the NRC worksheets have been compared with the computer file only for NRC licensees and DOEcontractors. For these items,100 percent accuracy was verified.

At approximately the same time this Bulletin is issued, the NRC will be sendinga letter to each non-licensee company that received apparently fraudulent ma-terial from Ray Miller, Inc. Appropriate portions of the fraud data file willbe included. These companies will be asked to identify any nuclear facilitythat may have been supplied the fraudulent materials. They will be asked torotify licensees, as appropriate, and the NRC by ,1983.

The actions listed below deal primarily with material included in the frauddata base file, however, the actions also include a request to examine and testa sample of other materials supplied by Ray Miller, Inc. that are still in stock,recardless of which Ray Miller branch office supplied the material. The basisfor this request is the need to compile and evaluate data on the quality of ship-ments that were presumed " legitimate." The results of this evaluation will beprovided to the nuclear industry on a timely basis.

Action Recuested of Nuclear Fuel Cycle Licensees (Except As Noted Below) andCategory B, Priority I Material Licensees:

This Bulletin is provided for information only. No specific action orresponse is required.

_Action Reouested of All Nuclear Power Reactor Facilities and Fuel Facilitiesholding an OL or CP:

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Within eight months of the date of this bulletin complete the actions identifiedin items'l through 4: ,

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IEB 83-June ,1983Page 4 of

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1. Based on a review of the attached lists of Ray Miller, Inc. customers whoreceived apparently fraudulent materials (Attachrents 1 and 2), andpertinent information obtained from any of these companies, either directlyor indirectly: *

(a) Identify those companies on the lists that supplied materials orservices to your facility (include subcontractors as well as majorcontractors);and

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(b) Determine whether any of the apparently fraudulent Ray Miller, Inc.materials were provided to or used at your facility.

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

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still in stock.

(d) If ouer Ray Miller, Inc. materials not listed in Attachments 1 and 2have been identified by your own initiative, determine whether any wasinstalled in safety-related systems at your facility, or is still in

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stock.

2. For apparently fraudulent materials (listed in Attachments 1 and 2)installed in safety-related systems of your facility:

(a) Evaluate the safety significance of the presence of frauduler.t materials(assume the fraud is as identified in the Attachments), and

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(b) Determine the disposition of the installed material; e.g., use as is,remove and replace, etc.

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

(a) Segregate into two groups: (1) material included in the purchase orderslisted in the fraudulent data file, and (2) all other materialsupplied by Ray Miller, Inc., regardless of the branch office thatsupplied the material.

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F,or the material included in the fraudulent data file:(b)

(1). -Discard the material, or

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To aid in this identification, a supplement to this Bulletin will be issued*

within 75 days from the date of this Bulletin to provide the results obtained,

I from the survey of non-licensee companies that received apparently fraudulentma terial . However, this does not relieve the licensees of the responsibility

; of contacting their suppliers to ascertain whether any of the material listedin Attachment I has been supplied to their facility.!

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(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 thefraudulent data file, do one of the following:

(1) Discard the material.,

(2) Tag or otherwise mark the materials for use,only in systems notimportant to safety, or

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(3) Subdivide material into groups of identical items and examineand test material in each group in accordance with either item(i) or (ii), below:**

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(i) Perform sufficient comprehensive examinations and tests toqualify each group of material for use in systems importantto safety. If there are less than 10 identical items in thegroup, each item should be examined. If there are 10 or moreidentical items, a statistical sampling plan may be usedto demonstrate with 90% confidence that 90% of the materialconforms to the purchase specifications. Groups ofmaterial found acceptable may be used as desired.

(ii) Perform comprehensive examinations and tests of a limitedsample of each group of identical items. The minimum samplesize is to be two items, or 10% of the items.in the group,whichever is greater. Examination and test of this limitedsample does not provide a high degree of assurance that theentire group satisfies the procurement specifications. TheNRC will compile the results of all the data received,determine the statistical significance of the results, andadvise industry of the overall results and conclusions.Therefore, a utility should not use this material in systemsimportant to safety until the NRC's evaluation is complete.

! 4. Provide a written report describing the results of the actions in items 1i ~through 3. Table 1 (Attachment 3) provides a suggested format for

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report,ing the results of the examination and testing of materials.

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Licensees are encouraged to perform examinations and tests rather than to**-

discard the material, even though the economic incentives probably favordiscarding the material. Data obtained in response to this Bulletin will becompiled by the NRC and disseminated to the industry. The extent to whichthis material deviates from its procurement specifications may be animportant consideration in evaluating the safety significance of Ray Miller,Inc. material not included in the fraudulent data file.

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Page 6 of

The written report requested by item 4 above should be submitted to theappropriate Regional Administrator under oath or affirmation under provisionsof Section 182a, Atomic Energy Act of 1954, as amended. In addition, the

original copy of the cover letters and a copy of the reports should betransmitted to the U.S. Nuclear Regulatory Commission, Document Control Desk,Washington, D.C. 20555 for reproduction and distribution.

Although the specific details involving apparently fraudulent materials receivedfrom Ray Miller, Inc. may not directly apply for your facility, you are requestedto review the general concerns expressed in the Bulletin for applicability atyour facility. Your response should describe the results of the review, andif the general concerns apply, you should describe the short-term and long-termcorrective actions to be taken and the schedules thereof.

This' request for information was approved by the Office of Management andBudget under clearance number 3150-0011. Comments on burden and duplicationshould be directed to the Office of Management and Budget, Reports Management,Room 3208, New Executive Office Building, Washington, D.C. 20503.

Although no specific request or requirement is intended, the following informationwould be helpful to the NRC in evaluating the cost of this Bulletin:

1. Staff time to perform requested review and testing.2. Staff time spent to prepare requested documentation.

If you have any questions regarding this matter, please contact the RegionalAdministrator of the appropriate NRC Regional Office, or one of the technicalcontacts listed below.

Richard C. DeYoung, DirectorOffice of Inspection and Enforcencnt

Technical Contacts:Mary)S. Wegner, IE(301 492-4511.

,Ronald M. Young, IE(301)492-9672

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Attachments:'l . Fraud File, Alphabetical by Buyer

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2. Fraud File, Buyer and Delivery Point Differ,-

Alphabetical by Delivery Point3. Table 1 - Material Examination and

Test Results4. List of Recently Issued IE Bulletins

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MATL SIZE CODES: 0 = 1" OR LESS1 : GREATER TilAH 1" AHD LESS TilAH DR EQUAL TO 2"2: GREATER TilAN 2" AND LESS TilAH OR EQUAL TO 4"3: GREATER THAH 4"

MATL TYPE CODES: PIPE = PIPING ,

TUDE : TUDINGFTFL : FITTING AND FLANGES -

FRAUD CODES: W = WELDED FOR SEAMLESSC = CARB0H CONTEllTF = FOREIGH FOR DOMESTICX r FORMillG OR MACili tli tlc SilR S T I Tit T I OilsP : l'RESSURE R ATINGST: ALL OTilERS

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NfPORIE IA IRAUD DAIA IIAst! All'lIA SL4111.llCE CUNDLil3 ti -

BUYLR DI:L I VI fiY l'Ollli H R Di~ R O R Di'R I tilli MAIL M A l l. l'R Alli) AllD/ COMMI.lli shat 1E/AUDR. II Alll / AllI)R . tillMill:R DAll: lillM 5171; ( Yl'l: CilDl!S IIR

ilEDI:LER 14ELDIllG' CO.~

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1025 JEFFER50ll AVEllUEBUFFALO,NY I4204 79P85-158087-1 05/02/79 01 0 TUDE W

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ABBE, PAUL 0. '.139 CEllTER AVENUELEFALLS,NJ 07424

ABBE, PAUL 0.

139 CENTER AVEllUELEFALLS,NJ 07424 P-29584-1928126 04/23/79 01 2 FTFL X

A28584 07/09/79 04 2 FTFL 'C

AFC0 METALSFOURCHE DAM PIKE A LINDSEY RD.LITTLE ROCK,AK 72203

AFC0 METALSFOURCllE DAM PIKE A LINDSEY RD.LITTLE ROCK,AK 72203 D 4944 03/02/77 Of 1 PIPE T REMARK

D 4944 03/02/77 03 0 FTFL T REMARK

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' AGRIC 0 CllEMICAL CO. .

P. O. BOX 1349 ,llENDER50ll, e

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AGRICO CllCHICAL CD.P. O. BOX 1349IlEllDFRSull,

KY 42420 FC 00713 03/31/77 01 1 FTFL REMARK-H'

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11UY LR DELIVLRY l'0INI UNDLR URULR L IIIE MAIL Mall iRAUD AllD/ cut 1MLH I S

NAME/ADDR. HAME/ADDR. HUNDER DATE HUM SIZE TYPE CODES OR-~

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ACRICO CHEMICAL CD.P. O. 80X 1349

'If ENDERSON,KY 42420 ,

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AGRICO CilEMICAL CO.P. D. BOX 1349

FC 00713 03/31/77 02 0 FTFL REMARK-H1IIENDERSON,

TR 40769 04/22/77 '01 1 FTFL C 304 FOR FKY 42420TR 40769 04/22/77 02 O FTFL X

FC 04814 09/09/75 02 0 TUBE W

AIM COMPANY .

I SMALLEY AVENUE.

MIDDLESEX,IfJ 08846

l AIM COMPANY1 SMALLEY AVENUEMIDDLESEX, 04/04/77 01 1 FTFL CT-0985NJ 08846

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AIR PREllEATER CD.PLANT ISMCLLSVILLE- *

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AIR PRElfEATER CD.PLANT E5

W-9070056 07/03/79 01 1 FTFL T 316 FOR }*WELLSVILLE,NY 14895

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MATL SIZE CODES: 0 : 1" OR LESS1 : GREATER TilAH 1" APID LESS TilAN OR EQUAL TO 2"2: GREATER TIIAH 2" AtID LESS TilAH OR EQUAL TO 4[3: GREATER TIIAH 4"

MATL TYPE CODES: PIPE : PIPINGTURE TUBINGFTFL = FITTING AND FLANGES

FRAUD CODES: W = WELDED FOR SEAMLESSC = CARDON CONTEllTF = FOREIGH FOR DOMESTICX = 00RMIllG OR NACllIIIIllG SUBSTITilTIONSP = l'RESSURE RATIllGST: ALL OTilERS

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BUYER DEL IVERY. I'0lHi ORDER ORDER LINE MATL MAIL f:RAUD AND/ COMMLi(IS~

NAME/ADDR. HAME/ADDR. HUNDER DATE ltUM SIZE TYPE CODES OR

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t1ID-VALLEY SUPPLY CO., INC.F. C. BGX 762.)RCHTON.

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Dil 65638- 04648 01/16/76 06 2 FTFL T 316 FOR 38* .

MUELLER, PAUL COMPANY0000 W. PilELPS'iP R ING FI EL D.MD 65801

D3000 05/03/78 02 1 FTFL X

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KIEFABER. W. II .I' . O. BOX 1226DAYTON,Ull 45401

AIR PRODUCTS AND CllEMICALS2500 YANKEE ROADMIDDLETON,011 45042 10-778088-DS 11/17/76 04 0 FTFL T

ALLEGilEHY POWER SERVICE CORP.CABIH llILLGREENSBURG,PA 15601

ALLEGilENY POWElb SERVICE CORP.FORT MARTIN POWER STATIDHMAIDSVILLE,WV 26541 20384 02/02/76 01 0 FTFL.

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REPORIE 5A rRAUD DATA DA52 CutlDEll5E BUYER / DELIVERY POIllT DIFFER

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nuYLR UL L IVI.RY l'Ulit i URDLR ORDLR L illE MAIL NAIL IRAUD AllD/ COMMLHISll AME/ A DDR . H Af1E/ A DDR . HUMBER DATE HUM SIZE TYPE CODES OR

: ALLEGilEHY POWER SERVICE CORP.i CARIll llILL

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ALLEGilENY POWER SERVICE CORP.FORT MARTIll POWER STATIONMAID 5VILLE,WV 26541 20384 02/02/76 02 0 TUDE W REMARK.

20515 02/23/76 01 TUBE20515 02/23/76 02 0 TUD2 W REMOVE20535 02/27/76 01 0 TUDE T REMARK154608 03/01/76 02 0 FTFL T 316 FOR 3154608 03/01/76 04 0 TURE W REMARK20536 03/12/76 08 0 FTFL C ELC FOR S15686 04/27/76 06 0 FTFL T 316 FOR 321158 05/28/76 02 0 FIFL T 316/304

NOH0HGAllEL A POWER CD.1310 FAIRM0HT AVENUEFAIRMONT,WV 26554

ALLEGilENY POWER SERVICE CORP.FORT MARIIN P0llER STATIONMAIDSVILLE,WV 26541 FM 18597 04/22/75 01 0 TUDE W

- FM 18597 04/22/75 02 0 T U D E- W' FM 19020 06/25/75 01 0 TUDE W

HrWMAHo 11. E.92 16 Til S T . , P.O. BOX 6208WilEELING,WV 26003

'ALLIED CilEMICAL CORP.ilHRill PL Alli , STAR RTE IlMOUllD5V I L L E,WV 26041 3566 06/02/77 01 2 FTI L X

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Attachment 3

TABLE 1

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Material Examination and Test Results

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Description of Material Examined & Tested (e.g., 1-inch Sc4 80 pipe),

Key Procurement Specifications (e.g. , Type 304 SS, low carbon)

Date of Purchase

Ray Ililler Branch Office That Supplied the Material

Quantity of Material in Stock

Quantity of Material Examined and Tested

Tests & Examinations Performed

Test Results(e.g., Material was Type 304 SS; however, the carbon content was 0.07%compared with a maximum of 0.04% carbon required by the procurementspecification.)

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To the Former Customers of Ray Miller, Inc.

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Gentlemen:

SUBJECT: Ray Miller, Inc.

The " Nuclear Regulatory Commission (NRC) requests your help in tracking apparentlysubstandard material which may have eventually been shipped to nuclear facilities.Our review of Ray Miller records has identified ycu as a customer to whom.sub .standard material may have been shipped. The following information brieflydescribes the problem, how it affects you, and hcw you can help.

Ray Miller, Inc. was a New Jersey corporation with main offices in WestCaldwell, NJ, and branch offices in South Charleston, WV, Buffalo, NY,Decatur, GA, and Skokie, IL. Ray Miller, Inc. was a distributor of stainlesssteel pipe, tubing, and fittings, and other specialty metal items from 1960to 1979. During that period, it was determined tnat the South Charlestonbranch office engaged in a number of fraudulent practices for which someofficers were subsequently indicted and convicted. These practices include,but were not limited to:4

1. Material type substitution: 304 for 315 and vice versa

2. Carbon content: standard'for low and vice versa

3. Origin: foreign for domestic

4 Tube manufacture type: welded and drawn for seamless

i ' 5. Pressure rating: 150# rating for 3000= or 6000#'

6. f4til test reports and other sworn certification falsification

7. Alteration of markings on material

8. Machining operations which may not have been authorized-

The NRC examined records of the South Charleston branch of Ray Miller, Inc.for the years 1975-1979-to identify all customers and to identify allevidence of material substitution or alteration. The substitutions or

i alterations which occurred are of interest to the NRC because of the| possibility that substandard material may have eventually been shipped to a! nuclear facility.

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An encicsure in this mailing is a computer printout (Enclosure 1) of the materialordered by you and/or shipped to you for which substitution or alteration issuspected to have occurred. Please examine the printout carefully. It containsdata for apparently fraudulent items only; the items were selected on the basisof notations made on the Ray Miller, Inc. work sheets which indicated thatunauthorized substitutions or modifications were made. The data include'

delivery point, purchase order number, order date, line number, raterialsize, material" type, fraud code, and comments. The purchase order number, .

if not your own, is the Ray Miller register number. The i; formation in eachcolumn is further described in the attachment to the data sheet. *

Please determine if you were the end user for all the material identified inthe computer printout. If you were the end user for all the items, pleaseanswer "yes" to Question 1 on the enclosed Questionnaire (Enclosure 2). If you

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supplied an item or items to another company or individual, please answerQuestion 1 "no" and identify each item by purchase order number and line number(as listed on the printout), giving the name and address of the customer to whomyou sold the item. It would be helpful in tracing the material if you couldgive us the customer's purchase order number and date. Please complete the formand return it to us in the enclosed postage-paid envelope within 30 days. Also,,

please notify your customer, particularly if you have reason to believe thatthe end user may have been a nuclear facility.

We will compile the responses we receive and make the information availableto nuclear facilities to assist them in their review of this matter. By othercorrespondence we are requiring licensees of nuclear power plants to determineif and where the material was used and the safety consequences of its use. If

necessary, it will be replaced. We can do this only with your aid and cooperation.

This request for information was approved by the Office of Management andBudget under clearance number .

Sincerely,

' Richard C. DeYoung, Director,

Office of Inspection cr.d Enforcement

Enclosures: .-1. Computer Printout'2. Questionnaire

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3. Envelope-,

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- REPORTR'18 FRALID DATA BASE ALPilA SEQUENCE O!IE l' AGE

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BUYER DELIV[RY Polill ORDLR DRDLR L liiE flAll 11All I R AllD AllD/ C0l111Lt415.HAME/ADDR. - N ATIE/ ADDR. fluf1 DER DATE .tlUt1 SIZE TYPE CODES OR

ABBE, PAUL 0.139 CEHIER AVENUE .

LEFALLS,HJ 07424 / , ,

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ABBE, PAUL 0.139 CEllTER AVEllUELEFALLS,

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NJ 07424 P-29584-1928126 04/23/79 01 2 FTFL XA28584 07/09/79 04 2 FIFL C

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j. 1. Were you the end user for all the items listed in the enclosedprintout?

2. If not, list the purchase order number and the item number and the name >

and address of the company or individual to whom you sold the item..,

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The order number column provides the buyer's purchase order number when thiswas available; otherwise, the Ray Miller, Inc. order number is provided.

; The order date column lists the date of the buyer's purchase order when thiswas available; otherwise, the Ray Miller, Inc. order date is listed.

The line numbeh column provides the .line number of the buyer's order for whic'hsubstitution or modification of material was apparently mate. .

The material size column is a code entry for the size of the material involved.For tubing, the size indicates the outside diameter. For pipe, the size indi-'

cates the nominal size. For fittings and flanges, the size normally indicatesthe tominal pipe diameter of the material, however, there may be someinconsistency in recording values in these cases. The codes are as follows:

Material size codes: 0 = 1" or less1 = greater than 1" and less than or equal to 2"2 = greater than 2" and less than or equal to 4"3 = greater than 4"

The material type column lists a code entry for the type of material involved.All items that were not piping or tubing were included in a category calledfittings and flanges. The codes are as follows:

Material type codes: PIPE = PipingTUBE = TubingFTFL = Fittings and Flanges

The fraud code column provides a code entry for the type of substitution ormodification that was apparently made. Dual or multiple entries for fraudcode indicate either substitutions of more than one type or that a determinationof which substitution was made could not be established from the informationavailable.

Fraud codes: W = Welded for Seamless- C = Carbon Content (Std. grades of stainless steel

for low carbon or in some cases low carbon- forStd.)

F = Foreign-made for Domestic-made,~

X = Forming or Machining performedP = Pressure Ratings substitutedT = All others, e.g., 304 SS for 316 SS

,

The and/or column indicates whether multiple entries for the fraud code aremultiple substitutions (and column) or a determination of which substitutionwas made could not be established (or column).

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CRGR PACKAGE FOR IE BULLETINAND LETTER TO NON-LICENSEES: RAY MILLER, INC.

1. BULLETIN

Proposed Generic Requirement

The NRC reviewed the available Ray Miller, Inc. records which covershipments made from the South Charleston, West Virginia branch officeduring the period 1975 to 1979, inclusive. The Ray Miller, Inc. recordsshowed that substitution of material had been made in some cases. Thedata on these shipments were compiled and computerized. (See proposedbulletin for details). The action required is the issuance of an IEbulletin to request actions of licensees with regard to possiblysubstandard material shipped by Ray Miller, Inc. The recommendedactions will identify the material, either justify its use or cause its

, replacement, and test material in stock.

Supporting Documentation

Attachment I contains copies of IE Information Notice 83-01 andSupplement I to that Information Notice which provide backgrounJ for thecase and a list of Ray Miller, Inc. customers.

Licensee Actions

The proposed bulletin recommends five actions by licensees: (1)determine if any substandard material was supplied to the facility, (2)locate the material which was delivered to the site, (3) evaluate thesafety significance of substandard material installed in safety systemsand its disposition, (4) segregate or discard substandard material still.

in stock, and (5) segregate or test a sample of the Ray Miller-suppliedmaterial still in stock and not on the fraud list.

Licensee Categories

The proposed bulletin is to be issued to all nuclear' power reactor andfuel facilities holding an operating license or a construction permit foraction and to other major fuel cycle licensees and Category B, Priority I

, (processors and distributors) material licensees for information.

Safety Benefit and Cost Assessment'

The safety benefit to be derived from the issuance of the proposed bulletinis the identification and evaluation of possibly substandard material whichmay have been shipped to nuclear facilities and installed in safety-relatedsystems or which may remain in stock at the facility. The licensee is-

requested to perform a safety evaluation of any possibly substandardmaterial that has been installed in safety-related systems. Where safety

Enclosure 3

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evaluation shows this to be necessary, substandard material will bereplaced, reducing the risk to public health and safety. Material instock will either be examined to assure that it meets all procurementspecifications, be discarded, or used only in systems not important tosafety. In summary, the requested action will reduce the risk to publichealth and safety by better assuring that the requirements of 10 CFR 50,Appendices A and B have been satisfied.

,

Implementing the recommended actions of the proposed bulletin will have amajor impact upon the licensees affected, but it is anticipated that only ,a few licensees will have received material from Ray Miller, Inc. Theimpact upon licensees for the determination as to whether they havereceived Ray Miller, Inc. material is significant with respect to the

. amount of time necessary to do a thorough record search. The followingis a discussion of the anticipated impacts:

Approximately 100 units will have to take some action because of thebulletin. Of this number, it is estimated that 80 should be impactedminimally by the requirements of the bulletin because they are not on thefraud list, did not receive apparently fraudulent materials from otherson the list, and did not receive materials from the other Ray Miller, Inc.offices. It is estimated that the effort of these licensees to documentthat they received no Ray Miller material is about 56 person-hours / unit.

Of the 100 units, it is estimated that 20 may be significantly impactedby the bulletin. It is estimated that 10 may have to expend 392person-hours of effort and 10 may have to expend 512 person-hours. Theseunits are assumed to have received apparently fraudulent materials andwill be required to review paper trails and evaluate the safety signif-icance of installed materials.

The overall impact on the industry is estimated at $811,000 for 13,520person-hours of effort (at $60/ professional person-hour) plus $100,000for material testing. Therefore, the total industry burden is estimated

~

to be $911,000.

.The impact of the bulletin on NRC resources is estimated to be about 200person-hours at a cost of $12,000. The majority of this effort will berequir.ed for IE review of safety evaluations performed by licensees andbulletin close-out efforts by the Regional Offices.

,

Priority

In accordance with the CRGR charter, this effort has been characterized-

as Priority B. A CRGR review schedule consistent with that priority isrequested.

Enclosure 3

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Existing Regulations

10 CFR 50 and Appendices A and B establish the regulatory bases forguidelines to determine that material installed in safety systems isspecified appropriately, properly manufactured and handled, properlyinstalled, and appropriately tested.

Methods of Implementation

The action proposed is to issue an IE bulletin to the specifiedlicensees. Responses are required from all addressees for action.Additional information developed by the NRC as a result of parallelefforts with non-licensee suppliers is to be furnished to affectedbulletin addressees to aid them in performing the requested actions.Review and evaluation of licensee responses will be coordinated by IEpersonnel to determine if all necessary actions have been taken toresolve this problem.

Time-Frame of Requested Actions

Because of the volume of records which the licensee may need to search andthe need for communication between licensee and supplier, a time length ofeight months has been given to complete the response to this bulletin.

II. LETTER TO NON-LICENSEES

proposed Generic Recuirement

The action required is the issuance of a letter to non-licensees torequest cooperation in locating fraudulent material shipped by Ray Miller,Inc. to them. The requested actions will aid in identifying the end userof the material.

Supporting Documentation

Attachment 1 contains copies of IE Information Notice 83-01 andSupplement 1 together which provide pertinent documentation of thegeneric problem from the time of the ccurt case.

_

Addressee, Actions

The proposed letter requests that addressees state that they were endusers of the Ray Miller material they crdered or received, or assist the

,

NRC in locating the customer to whom they sold the material in order tolocate the end user.

Enclosure 3.

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Addressees of the Letter ,

The proposed letter is to be issued to customers of Ray Miller, Inc. whoapparently received fraudulent materials from the South Charleston, WestVirginia branch office during the period 1975-1979, as detenained from asearch of available Ray Miller, Inc. records. Four hundred, fifty-four

companies,were identified. Four are DOE facilities, eight are NRC licensees(five associated with power reactors) leaving a total of 442 designated *recipients of this letter. Of this number, six are nen-nuclear facilities,of a company that is a licensee.

Cost Assessment

. The benefit to be derived from the issuance of the proposed letter is thefacilitation of the bulletin response and a greater probability ofcompleteness.

The impact upon non-licensees is generally very minor. Those who wereend users 'of the material would expend, on an average, less than an hourof their time in responding. Suppliers to nuclear facilities would needtime to search their records and to prepare a response to the NRC and tonotify the involved facility; probably less than 40 hours, on anaverage. Suppliers to nuclear facilities are expected to be less than 10percent of the addressees of the letter. The overall impact on thenon-licensee industry is estimated at 5126,000 for 2100 person-hours ofeffort (at $60/ professional person-hour).

The impact of the letters to non-licensees on NRC resources is estimatedto be about 115 person-hours at a cost of $6900. This effort is expectedto be rather equally divided among compilation of negative reports (largenumber with small effort), documentatitn and distribution of datainvolving nuclear facilities (small number with larger effort), andfollow-up with companies not responding to the initial letter.

Priority

.Sare as bulletin.

.Existing Regulations

10 CFR 50'and Appendices A and B establish the regulatory bases forguidelines to determine that material installed in safety systems isspecified appropriately, properly manufactured.and handled, properlyinstalled, and appropriately tested.-

Enclosure 3

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Methods of Implementation

The action proposed is to issue a letter to the specified non-licensees.Responses are requested from all addressees. Additional informationdeveloped by the NRC as a result of this effort is to be furnished toaffected addressees of the proposed IE bulletin to aid them .in developingresponses. Review and evaluation of non-licensee responses will becoordinated by IE personnel in Headquarters.

Justification for Time-Frame of Reouested Actions

Non-licensee responses are requested within 30 days of the receipt of theletter. These responses are needed to assure that nuclear facilities are

' made aware of the apparently fraudulent material provided to them. Theresponses will be compiled by IE and furnished to affected licansees within75 days of the issuance of the letter to aid licensees in complying withthe bulletin. Because compulsion under law is inappropriate, follow-up incase of lack of response will be done by letter and/or by telephone.

Attachments:1. Information Notice 83-012. Information Notice 83-01, Supplement 1

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SSINS No.: 6835.

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. IN 83-01

UNITED STATES-

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NOCLEAR REGULATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D. C. 20555

January 26, 1983-

IE INFORMATION-NOTICE NO. 83-01: RAY MILLER, INC..

Addressees:

All holders of a nuclear power reactor or fuel facility operating license (OL)or construction permit (CP).

Purpose:

This information notice is provided as an early notification of a potentiallysignificant problem pertaining to fraudulent products that may have been soldto nuclear industry companies by Ray Miller, Inc. This problem may affectboth PWR and BWR facilities. The Nuclear Regulatory Commission staff isreviewing the problem and its effects. If the evaluation so indicates, theNRC may request explicit licensee or CP holder action. In the interim, we ,

expect the addressees of this information notice to review the informationherein for applicability to their facilities. No specific action or responseis required at this time,

Description of Circumstances:

A. Background

During November 1982, the Nuclear Regulatory Commission became aware thatRay Miller, Inc., Charleston, West Virginia had been systematicallydefrauding its customers, including some nuclear industry companies, bymarketing 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 Courtin Charleston, West Virginia to 10 felonies: six counts of mail fraud and ffour 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

Virgin,ia; Decatur, Georgia; Buffalo, New York; and Skokie, Illinois.The Ray Miller office in Charleston, West Virginia was stated to be theonly office with equipment capable of making alterations of markings onmaterials. The firm had been under investigation by special FBI agents

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for three years before prosecution by the Office of U.S. Attorney, '

Charleston, West Virginia.

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IN 83-01January 26, 1983Page 2 of 4

The precise number of nuclear-related businesses that may have beendefrauded by Ray Miller, Inc. remains an unknown. Records are incompleteand the situation is further complicated by the firm ceasing to operateand 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 periodbefore the FBI began its probe in July 1979. Under the terms of the pleaagreement, 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. =

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Some of the nuclear industry companies appearing on an FBI generated listof Ray Miller customers for the year 1979 include Babcock and Wilcox,Combustion Engineering, Goodyear Atomic, Tennessee Valley Authority,

. Virginia Electric and Power (VEPCO), and Allied Chemical (at Barnwell).

VEPCO and Barnwell are aware of the Ray Miller problem. VEPC0 has placedsuspect fraudulent material, which had not been installed, on hold.

B. Discussion

Specifically, the scheme to defraud as practiced by Ray Miller, Inc. fromapproxmiately 1960 to 1979 was exposed by an extensive investigationconducted by the Federal Bureau of Investigation. The primary practiceswhich formed that scheme, as detailed by the FBI, are as follows:

1. Markings on pipes and nipples indicating the foreign country wherethe product was manufactured were removed and the pipes and nippleswere sold as domestic-made products.

2. Stainless steel (304 and 316) couplings, flanges, and bushingshaving ctandard carbon content were altered by imprinting an "L",

making the marking on couplings, flanges and bushings appear as lowcarbon content materials.

3. Falsely notarized documents were prepared with billings, certifyingthat the materials shipped were of low carbon content when in factthey were not.

.

4. Welded and drawn tubing was altered by removing the markings "WD"- from this product and it was sold as seamless tubing.

TheRayIillerrecordsweremadeavailabletotheNRCafterthecompanyofficers who pleaded guilty were sentenced on December 23, 1982. OnJanuary 6 and 7,1983, members of the MC met With the FBI and the

,

Assistant U.S. Attorney in Charleston, West Virginia to discuss the RayMiller, Inc. case and to review a sample of the 29 boxes of recordscurrently in the custody of the FBI. These records cover the period from1975 to 1979. After 1979, Ray Miller, Inc. apparently ceased its frau-'

dulent practices. The NRC is checking on the availability of records thatpre-date 1975.

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IN 83-01January 26, 1983Page 3 of 4

During the sampling of records by the NRC, the following addiLionaldocumentation of product substitution was identified: machined itemswere sold as forged ones, and materials with a low capacity to withstandpressure, i.e., 150 psi pipe plugs, were sold as materials capable ofwithstanding much greater pressures, e.g., 3000 psi pipe plugs. Some ofthe invoices reviewed by NRC, representatives and used as undeniableevidence by the U.S. Attorney's Office, were found to actually have thewritten" notation, " Remark", indicating product fraud. '

.

Primarily, the NRC representatives attempted to ascertain the extent that'Ray Miller's fraudulent practices may have impacted nuclear-relatedcompanies. Based on a sampling of the records, the NRC staff reached thefollowing very general conclusions:

'

1. It appears that Ray Miller, Inc. supplied products to only a fewcompanies directly involved in the nuclear power industry. However,the full extent to which the firm's products may be used in thenuclear industry is not known, since these products were sold tomany jobbers and distributors.

2. Most shipments which were received directly by nuclear-relatedbusinesses were relatively small.

3. Generally, only a small partion of Ray Miller products purchased bynuclear industry companies appears to be fraudulent.

A search of the License Event Report file has been conducted by the4

National Science Information Center (Oak Ridge, Tennessee) for the NRCand no instances were identified in which nuclear facilities havereported deficiencies attributed to Ray Miller, Inc. materials.

C. Guidance

Enclosed for your information and appropriate action is a list from theCharleston 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 bran h "fices were sometimesr

- filled by the Charleston office. A composite 1;(L customers for otheryears 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

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resources from various sectors of the nuclear industry and 00E to providea detailed examination of all Ray Miller records known to exist. Itis conjectured that these efforts will yield useful information for

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IN 83-01 ;. .

. January 26, 1983Page 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 thesematerials.

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dwar L. ordan, DirectorDivisio f Emergency Preparedness

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and E ineering ResponseOffice of Inspection and Enforcement

:

Technical Contact: R. M. Young, IE301-492-9672

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Attachments:1. List of Ray Miller Customers for 19792. List of Recently Issued IE Information Notices

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Attachment 1-

Itt 83-01.

January 26, 1983Page 1 of 8

The followng are custer.ers of the P.ay Miller Corporation forthe year 1979: (With the exception of inter-cocpany accounts).

Alcoa Center ,7th Street Rd.Route 750 -

Alcoa Center, Pennsylvania 15069 ,

Allegheny Power Service CorporationCabin HillCreensburg, Pennsylvania 15601

Allied ChemicalSpecialty Chemicals DivisionNorth Gate, State Route #1Moundsville, West Virginia 26041

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Allied Ceneral Nuclear ServicesBarnwell, South Carolina 29812

Appalachian Power CoupanyP.O. Box 2021P.oanoke, Virginia 24022

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Aqua Chem., Inc.240 West Capitol DriveMilwaukee, Wisconsin 53212

Arge Welded ProductsAlpha Industrial ParkPhillipsburg, New Jersey 08865

Ashland Synthetic Fuels, Inc.?. O. Box 391 .

Ashland, Kentucky 41101.

Avtex Fibers, Inc.Plant ReadNitro, West Virginia 25143

Babcock and Wilcox Company'

609 Wcrren AvenueApollo, Pennsylvania 15613

:BASP Vysndotte CorporctionPignents Division24th Street and 5th AvenueF.untington, Wes- Virginia 25722.

.,

Feaunit Fabrics Corporation~P. O. Box 791>

Statesville, North Carolina 28677

Bendix Corporation .

U.S. 219 North'

Lewisburg, West Virginia 25901

Bethlehem Steel CorporatienJohnstown, Pennsylvania 15907

Brighton Cor oration11861 Mostel.er RoadCincinnati, Ohio 45241

Calson Corporation .

P.O. Eox 1346-

.Pittsburgh, Pennsylvania 15230

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Page 2aof 8

Casale Industries:00 South AvenueCar.oed. New Jersey 07027

C. E. 7turston and Suns. Inc.P.O. Box 963F.ichmond, Virginia 23207

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Celanese Fibers CompanyP.O. Sox 2334Charlotte, North Carolina 28234. -

Central Suppliers, Inc.1624 Debaun Avenue *

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Chesapeake, Virginia 23320

Cepeda Associates, Inc.1E23 Laser LaneLouisville, Kentucky 40299

* CF IndustriesU.S. 41 NorthTerre Haute, Indiana 4780S

Cha= pion PapersCha= pion International CorporationCanton MillCanton, North Carolina 28716

1

Che:etron CorporationPignents DivisionP.O. Box 2166Euntington, West Virginia 25722

Chesapeake Corporation of VirginiaWest Point, Virginia 23181

,

Cincinnati Fasteners Co=pany.

16 Eas t 73rd StreetCincinnati, Ohio 45216

C&!/Cirdler. In c.P. O . Box 32940icuisville, Kentucky 40232

Cofsco, Inc.P.O. Box 184*'cos te r. Ohio 44691a

. Cc=bustion Engineering. Inc. -

| M:nogahelia, Pennsylvania 15063-

* Continental Can Cc=pany, In c.P. O. Box 201Mopewell, Virginia 23860

CVI CorporationF.C. Box 2138 ,

'Columbus, Ohio 43216

Cyclops IndustriesF.O. Box E614South Charleston, West Virginia 25303

Dayton Power and Li;ht Co:panyC:urthouse Pla:a, ScuchwestF.O. Sox 1247Oayton, Ohio 45401

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SSINS No.: 5340/6835IN 83-01. Supp. 1

UNITED STATESNUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENTWASHINGTON, D. C. 20555

April 15,1983

IE INFORMATION NOTICE NO. 83-01, S.UPPLEMENT 1: RAY MILLER, INC.

Addressees:''

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All holders of a nuclear power reactor operating license (OL) or construction 'permit (CP), nuclear fuel cycle licensees and Category B, Priority I material

.. licensees.

Purpose:

This information notice is a supplement to IE Information Notice No. 83-01,issued on January 26, 1983. This generic communication provides an expandedcustomer list and information related to a potentially significant problem in-volving fraudulent products that may have been sold to nuclear industry com- |

panies by Ray Miller, Inc. of Charleston, West Virginia. The sale of fraudulent;

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materials may have been direct to nuclear industry companies, or indirect,e.g., supplied through several tiers of subcontractors.

| Planned Future Actions:)

( This information notice is being issued as an intermediate step. Actions1 planned for the near future include issuance of an IE Bulletin to reactor or

nuclear fuel cycle licensees with an enclosed computer listing of all purchaseorders that apparently involve fraudulent substitution of materials. At approxi-mately the same time, NRC plans to send a letter to each nonlicensee company that

,received apparently fraudulent material from Ray Miller with specific inform- |

ation on the purchase order number, date, and type of fraud apparently committed.These purchasers will be requested to provide information to the NRC identifyingany NRC reactor or nuclear fuel cycle licensees that may have been supplied '

fraudulent materials.

Discussion:

-On February. 25, 1983, members of the NRC completed a detailed review of the29 boxes of Ray Miller, Inc. records that are under the custody of the U.S.Attorney's Office in Charleston, West Virginia. The results of this reviewhave been inputted into computer data files. The information that is immediatelyavailable includes a more comprehensive customer list than that provided with IEInformation Notice 83-01, and a designation of those companies that apparently-

received fraudulent materials. This list is provided in Attachment 1.

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IN No. 83-01, Supp. 1~April 15, 1983 '

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Page 2 of 2

The attached updated customer list enumerates those customers that receivedmaterials from the Charleston, West Virginia office during the period 1975-1979.The presence of a company's name on this list does not necessarily mean that itreceived fraudulent material, only that the company was a customer of Ray Miller,Inc. of Charleston or received materials directly from the Charleston office.However, there is not absolute certainty that orders were filled as specified,because notations on the work sheets may not have been recorded in all cases.Notations were generally written onto the work sheets when substitutions weremade.

The designation of those companies that apparently received fraudulent materialsis shown'by an asterisk on the customer list. A review of notations on the worksheets indicate that substitution of material apparently occurred for part ofat least one order placed by these companies during the period 1975-1979. Detailsconcerning these apparently fraudulent shipments will be provided to thosecomp'anies who may have received such shipments, as soon as further sorting andevaluation of the data file is completed.

If you have any questions regarding this matter please contact the RegionalAcministrator of the appropriate NRC Regional Office or this office.

%&tdw r . Jordan, DirectorDivisi n of Emergency Preparedness

and Engineering ResponseOffice of Inspection and Enforcement

Technical Contact: Ronald M. Young, IE(301) 49-29672

Attachments:1. Updated Customer List2. List of Recently Issued Information Notices

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: '03/22/83 HAME 8 ADDRESS LISTING PAGE I 03/22/83 NAME 8 ADDRESS LISTING PAGE 2 Attachment 1

(ALL CUSTC;;2RS: 30-FRAUD AND FilAUD) (ALL CUSTOMERS HO-FRAUD AND FRAUD) IN 83-01, Supp. 1April 15,1983.

'.page 1 of 68A AND A RUBBER CORP. ADAMS, RP CO. INC.

533 WRIGH1 WOOD 2225 E. PARK ROAD '

ELMHURST, BUFFALO,IL 60126 HY 14240

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A AND E WELDING EAFCG METALS1225 BLOOMFIELD AVENUE FOURCHE DAM PIKE & LINDSEY RD.FAIRFIELD, LITTLE ROCK,NJ 07006 AK 72203

A AND I SUPPLY CD. AGRI-CHEMICALS614-616 VIRGINIA ST. WEST 204 W. MAIN sCHARLESTON, BELMOND,WV 25330 IO 50421

A. O. A. BURD0X INC. AGRICO CHEMICAL CO.VERDIGRIS PLANT, ROGER CHTY.

BUFFALO, CAT 0OSA,NY OK

aABBE, PAUL 0. & AGRIC 0 CHEMICAL CA.139 CENTER AVENUE P. O. BOX 1349LEFALLS, HENDERSON,NJ 07424 KY 42420

ABBOT LABS~

AGWAY INC.14TH ST. AMD 5HERIDAH RD. HOWARD STREETH. CHICAGO, BATAVIA,IL 60064 HY I4020

ACCURATE MACHINE PROD. CORP. AGWAY INC.710 WEST WALHUT STREET FERTILIZER DIV., COLE ROADJOHHSON CITY LYOH,TN 37601 NY 14489

ACR0 MACHINE CD. AGWAY INC.A AND VENANGO STS,PHILADELPHIA. TARRTOWN,PA 19134 PA 16201

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/22/83 NAME 8 ADDRESS LISTING PAGE 3 03/22/83 HAME & ADDRESS LISTING PAGE 4 Attachment 1(ALL CUSTOMERS: HO-FRAUD AND FRAUD) (ALL CUSTOMERS: HO-FRAUD AND FRAUD) IN 83-01, Supp. 1

April 15, 1983..

., Page 2 of 68AGWAY INC. ALC0A

.

WEST HIGH STREETUNION CITY, MASSEHA,

lPA 16438 NY 13662t i r

ALCOA CENTERAILEEN INC. 7TH ST. RD; RTE 780ACCOUNTS PAYABLE SECTION ALCDA CENTER, *EDIMBURG,

PA 15069'VA 22824

ALL STAIHLESS INC.iAIM COMPANY 75 RESEARCH ROAD1 SMALLEY AVENUE HINGMAN,MIDDLESEX, MA 02043HJ 08846

WALLEGHENY POWER SERVICE CORP.'

) AIR PREHEATER CD. CABIH HILL'

PLANT 85 GREENSBURG,.WELLSVILLE,PA 15608

NY I4895

AIR PRODUCTS AND CHEMICALS 1F ALLEGHEHY POWER SERVICE CORP.FORT MARTIN POWER STATIDHCIVIC INDUSTRIAL PARK MAIDSVILLE.LA SALLE, WV 26548 ,

IL 61301,

AIR PRODUCTS AND CHEMICALS gALLEN METAL155 LIBERTY AVENUEHOUDRY LAB BROOKLYH. 8LIHWOOD,NY 18212

PA 19061

ALLIED CHEMICAL CORP.J AIR PRODUCTS AND CHEMICALS 40TH ST. & WIHCHESTER AVE.2500 YANKEE ROAD ASHLAND,MIDDLETON, KY 4f108OH 45042

AIRTECH INC. q[ ALLIED CHEMICAL CORP.35 LEE STREET17 W. SCOTT STREET BUFFALO,RAHWAY, *

HY 14210NJ 07065 * ,

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