EXTRANCHECK: POST-SHIPMENT VERIFICATION: HINDUSTAN

UNCLAS NEW DELHI 000178 SIPDIS SIPDIS USDOC FOR 532/OEA/M. NICKSON-D/JAY HATFIELD USDOC FOR 3131/USFCS/OIO/ANESA/KREISSL USDOC FOR 4530/MAC/ANESA/OSA ICE HQ FOR STRATEGIC INVESTIGATIONS STATE FOR EB/ESP E.O. 12958: N/A TAGS: ETTC ETRD BEXP IN SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: HINDUSTAN AERONAUTICS LTD., FOUNDRY & FORGE DIVISION, BANGALORE, LICENSE NO. D357622 REF: USDOC 09452 ¶1. Unauthorized disclosure of the information provided below is prohibited by Section 12(c) of the Export Administration Act. ¶2. On November 26, 2007, Export Control Officer (ECO) Paul Cushman and BIS FSN Prem Narayan conducted a Post-shipment Verification (PSV) at Hindustan Aeronautics Ltd. (HAL),Foundry & Forge Division (F&FD),Bangalore. ¶3. BIS requested a PSV at HAL F&FD, an entity within the Ministry of Defence (MOD),GOI. HAL F&FD was listed as the ultimate consignee for a titanium alloy (Ti-6A1-4V) controlled under ECCN 1C202. The license applicant was ALLVAC, Inc. (ALLVAC),Monroe, North Carolina. ¶4. ECO and FSN Narayan met with V. Swaminathan, Chief Manager, Integrated Materials Manager (IMM) and Fernandez, Senior Manager, HAL. Randhir Jaiswal, Deputy Secretary (AMS),Ministry of External Affairs (MEA),facilitated the meeting. Jaiswal was also present at the meeting. ¶5. HAL officials stated that they regularly source titanium alloy from ALLVAC. HAL officials provided documentation for multiple transactions, which exhausted the subject license. They also stated that the manufacturer is never able to supply the exact quantity ordered. It is produced in batches that can vary up to ten percent, more or less than the quantity requested. This potential variation is a condition agreed to by both sides before the order is filled. ¶6. Details of the consignment documents provided by HAL are listed below: (a) HAL Purchase Order No. 2/20/3013/1 for 10,770 kgs, against ALLVAC Invoice No. 07575233 for 11,672 kgs and HAL Receiving Report confirming receipt of 13,048 kgs. (b) HAL Purchase Order No. 2/20/3029/1 for 5,000 kgs against ALLVAC Invoice No. 07577064 for 5,466 kgs and HAL Receiving Report confirming receipt of 6,097 kgs. (c) HAL Purchase Order No. 2/20/2576 for 13,000 kgs, against ALLVAC Invoice No. 07577065 for 13,471 kgs and HAL Receiving Report confirming receipt of 14,280 kgs. Note: the HAL Receiving Reports reflect the HAL Purchase Order Number and Supplier's Invoice Number. Packing materials account for the discrepancy between weights listed on the invoices and the receiving reports. ¶7. HAL officials provided a copy of the completed form BXA-711 for this transaction. Swaminathan confirmed the stated end-use. The alloy was used to manufacture components for aircraft engines and helicopter transmission systems. Swaminathan stated that all of the titanium alloy purchased under subject license has been consumed. To illustrate his point, he provided a computer-generated disposition log for the Ti-6Al-4V obtained under this license. ALLVAC provided to HAL F&F a copy of the export license with the license conditions listed on it. ¶8. Established in 1953, HAL Foundry & Forge Division manufactures castings, forgings, rolled rings, brake-pads and rubber products for the aeronautics, space, defense, locomotive, heavy equipment and other industries. The division has the infrastructure and expertise to manufacture radiographic-quality castings to international standards. The majority of their work involves alloy fabrication, semi-continuous cast billets, aluminum alloy castings and magnesium alloy castings. The Foundry and Forge Division employs approximately 695 personnel. ¶9. Recommendation: Based on the interview with HAL officials and a careful review of the supporting documents they provided, it appears that HAL's Foundry and Forge Division received and consumed the listed commodity in accordance with the conditions of the license. However, because a physical inspection of the listed commodity could not be accomplished, this Post-shipment Verification remains inconclusive. MULFORD