Presentation on theme: "1 Counterfeit, Suspect, Fraudulent Item (CSFI) Developing the NRC CSFI Response Community DOE Conference Call Nov. 11, 2009 Daniel Pasquale Sr. Operations."— Presentation transcript:
1 Counterfeit, Suspect, Fraudulent Item (CSFI) Developing the NRC CSFI Response Community DOE Conference Call Nov. 11, 2009 Daniel Pasquale Sr. Operations Engineer Quality and Vendor Branch Office of New Reactors
2 Generic Communication IN Counterfeit Parts Supplied To Nuclear Power Plants The 3 characteristics of an effective procurement and dedication plan: 1)The involvement of engineering staff in the procurement and product acceptance process; 2)Effective source inspection, receipt inspection, and testing programs; 3)Thorough, engineering-based programs for review, testing, and dedication of commercial-grade products for suitability for use in safety-related applications.
3 Program Strategies The Defense Self Assess – and be critical Encourage a questioning attitude Perform thorough receipt inspections –Verify procurement requirements Provide CSFI training to QA/QC receipt inspectors Make Current CSFI information available Maintain a comprehensive CGD program
4 Program Strategies The Offense Self Assess – and be critical Zero tolerance policy for counterfeiting Supplier selection –Know your suppliers (Upstanding) –Assess suppliers return & scrap/disposal policies Precise procurement specifications based on engineering input IT protection of Intellectual Property Community Watch programs –Outreach efforts
5 Some Proactive Best Practices Protect Your Intellectual Property –Register patents & trademarks –Impose strong IP procurement clauses including specific CSFI language –Question the suppliers IP controls –Institute anti-fraud techniques Maintain Robust Procurement Controls –Perform vigilant receipt inspections that include CSFI elements –Include a CSFI element for repair/returns receipt inspections –Control disposal of process scraps, rejects, un-repairable returns etc –Trust but verify Know Your Suppliers –Use O.E.M. authorized distributors –Employ rigorous supplier selection processes –Maintain short supply chains
6 Communicate and Maintain Relationships with the O.E.M –Seek O.E.M. assistance In detecting CSFI –Ensure that the O.E.M. also has a robust CSFI program Take Action –Report known or suspected Counterfeiting –Guard Intellectual Property –Take appropriate legal actions Stay Current –Monitor counterfeiting news –Participate in related industry committees –Share information The NUPIC Vendor Interface Committee Meeting June 17 & 18, 2009 Some Proactive Best Practices
7 1.Issuance of IN , Counterfeit Parts Supplied To Nuclear Power Plants (April 7, 2008) 2.Developing the NRCs CSFI community (June 4, 2009) 3.Continuing to enhance the NRCs Vendor Inspection program 4.Working with NUPIC to enhance their audit process 5.Working with EPRIs Technical Advisory Group (TAG) on CSFI 6.Cooperating with DHSs Anti-Counterfeiting task forces 7.Improving communications and sharing information with the nuclear community WHAT IS THE NRC DOING?
8 A community-based organization working together to combat CSFI activity: –Take positive steps –Share current information of new trends in CSFI –Establish consistent programs for combating CSFI activity – Awareness of & access to the various related government agencies –Develop industry standards –Evaluate CSFI claims –Training for Inspectors, Purchasers and QA personnel COMMUNITY WATCH PROGRAMS
9 NRO, Quality & Vendor Branch-BWR NRO, Quality & Vendor Branch-PWR NRR, Vendor Branch – Operating Units NMSS/SFST – Nuclear Fuel Storage NMSS/FCSS – Nuclear Fuel Transport OpE (Operational Experience) ConE- (NRC-Construction Experience) OI (Office of Investigations) OAC (Office Allegations Coordinator) OE (Office of Enforcement) ADM/DC (Excluded Parties List) NRC Regions IRS/IAEA (International Reporting System) ConX- (NEA-Construction Experience) DEVELOPING THE NRCS CSFI COMMUNITY Internal NRC Family – 1 st Tier
10 The NRCs CSFI Community TIER 1 (Family)TIER 2 (Neighborhood)TIER 3 (Associates)TIER 4 (Global) NRO/CQVBNEIDIAIAEA NRR/EQVBINPO GIDEP db IRS db NMSS /SFSTEPRIUS COC (CACP)US COC (GIPC) NMSS/FCSSNUPICUS DOD (DCIS)US DOC (BIS) NRC Event Reporting Program NIACUS Navy Dept (BMPCOE) INTERNATIONAL NUCLEAR REGULATORS Part 21 dbEEIUS DHS (ICE)US TR (E&ES ITAC) OpE dbUS DOEUS DHS (CBP)US TR (AE&CG ITAC) ConE db S/CI dbUS CPSC dbUS PTO (FQA Markings) ConX dbUS DOC (ITA)US GAO (EPLS db)WTO Morning Reports db STOPFAKES.gov dbUL dbWIPO NRC OINIST (FQA)NIST (MEP)APICS US DOS (IPR TP)NAM NEMA IPRTP ICC (CIB) INTERPOL
11 Department of Defense Government Information Data Exchange Program (GIDEP) Diminishing Sources and Material Shortages (DMSMS) NASA Aerospace Standard AS5553, Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition Department of Energy Suspect/Counterfeit or Defective Items Program (S/CDI) Occurrence Reporting and Processing of Operations Information (ORPS) Department of Commerce International Trade Administration, Office of Energy and Environment Manufacturing & Services Bureau of Industry & Security, Office of Technology Evaluation Nuclear Procurement Issues Committee (NUPIC) Commercial Nuclear Power Licensees & Suppliers Nuclear Energy Institute (NEI) Electric Power Research Institute (EPRI) Outreach Efforts
12 10 CFR Part 21 Reports - NRC OpE: Operating Experience – NRC ConE: Construction Experience - NRC OpEx: Operating Experience - INPO EPIX: Equipment Performance & Information Exchange-INPO GIDEP: Government Industry Data Exchange Program SCI: Suspect & Counterfeit Items – DOE EPLS: Excluded Parties List System - GAO CPSC: Consumer Protection Safety Commission TheTrueCosts.org: U.S. COC STOPFAKES.gov: Joint Effort hosted by DOC IRS: Incident Reporting System – IAEA ConX: Construction Experience - NEA EXISTING DATA SOURCES
13 NOW IS THE TIME TO SHARE CSFI INFORMATION I have suggested before that this kind of information (defective, counterfeit, or mis- used components) should be collected by all regulators and shared across national borders. Today I will modify my view by saying that this is not merely a good idea, but perhaps even a necessary one. - NRC Commissioner and Former Chairman Dale E. Klein at the IAEA General Conference Senior Regulators Meeting, Vienna, Austria, October 3, 2008
14 SUMMARY The threat of CFSI is real – and growing Industry vulnerabilities are growing also Maintain a robust CSFI program –Refer to current NRC guidance –Protect your Intellectual Property (IP) –Incorporate Best Practices Build and maintain a solid CSFI community –Federal agencies –Industry communities –Supply chain
15 QUESTIONS Daniel Pasquale Sr. Operations Engineer Quality and Vendor Branch Office of New Reactors