White Paper: Mitigating the Risk - CFSI
Background
The problem facing the nuclear industry in the area of “Counterfeit, Fraudulent and Substandard items” (CFSI), although becoming more prevalent, is nothing new. Back in 1989, the Nuclear Regulator Commission (NRC) issued Generic Letter 89-02 entitled, “Actions to Improve the Detection of Counterfeit and Fraudulently Marked Products” The letter was directed to all holders of operating licenses and construction permits for nuclear power reactors.
In May 1990, the Electric Power Research Institute, (EPRI), published “NP-6629, Guidelines for the Procurement and Receipt of Items for Nuclear Power Plants”. This document contains additional information in Appendix C, “Identifying Substandard/Fraudulent Items”.
So far, due to the rigorous quality assurance programs required to be in place at nuclear power plants, no counterfeit or fraudulent items have been discovered installed in safety-related applications. How long will this remain to be the case without both suppliers and the utilities taking further steps to mitigate the risk? This problem is not going away.
Counterfeit items, which have entered the nuclear system in the non-safety related arena, include valves, integrated circuits, breakers, and capacitors.
The nuclear utilities in 2009 began to enhance their quality audits with a revision to the Nuclear Procurement Issues Committee (NUPIC) checklist to include a section on CFSI. The expectation is for suppliers to have methods in place to address the issue. The absence of processes addressing CFSI in a suppliers QA program is now resulting in findings by NUPIC audit teams. Shortly afterwards, the Nuclear Industry Assessment Committee (NIAC), a group of nuclear industry suppliers, followed the NUPIC lead and revised their audit checklist, in an attempt to trickle down the requirements to their suppliers. In a recent development, CANPAC has issued a letter to all suppliers on their database regarding the CANDU owners concerns and to make suppliers aware that CANPAC will now be auditing for anti CFSI measures.
