(Continued on page 20)
Counterfeit
Items &
Computer
Program
Dedication
By Marc Tannenbaum, Electric Power
Research Institute.
Marc
Tannenbaum
Marc Tannenbaum
is a Senior Project
Manager in the Plant
Engineering program
area of the Nuclear
Sector at the Electric
Power Research
Institute (EPRI).
He is responsible
for research in the
areas of procurement
engineering and supply
chain management.
His current research
focuses on improving the quality of
procured items, commercial grade item
dedication, the technical aspects of
materials management and proactive
management of obsolescence and
inventory to support equipment
reliability.
Tannenbaum joined EPRI in 2007. Prior
to joining EPRI, he consulted with EPRI
and delivered several of EPRI’s nuclear
procurement training courses.
Tannenbaum received a Bachelor of
Science degree in Industrial Engineering
and Business Administration from the
University of Illinois.
An interview by Newal Agnihotri,
Editor of Nuclear Plant Journal at
the American Nuclear Society Utility
Working Conference in Hollywood,
Florida on August 12, 2013.
1.
With the global supply chain, how
are counterfeit items figured out?
The transition over the years from
vertically integrated business models to
the global nature of today’s supply chain
(where the materials and parts involved in
the manufacture of a single item can be
sourced from locations around the globe)
certainly opens the door to those willing
to make a quick profit through fraudulent
activity.
Un f o r t u n a t e l y,
there is no single
foolproof way to detect
non-genuine
items.
An effective defense
involves measures to
prevent and detect items
suspected of being
fraudulent, as well as
measures to control
suspect items when
they are identified.
I’d say one of the
most important aspects
of defense is awareness
and training of key personnel. Another
is documenting and sharing information
on incidents of suspect items. Both of
these play a role in prevention, detection,
and control. A third is developing
the capability to identify “at-risk”
procurements and implement appropriate
precautionary measures.
2.
What are the major controls that
utilities have to ensure that counterfeit
items do not get into their inventory?
First and foremost, suppliers of
safety-related items are subjected to
a thorough qualification process, so
licensees know the most important
suppliers very well and verify their
practices through comprehensive audits.
When distributors or agents are involved
in the procurement process for safety-
related items, they are also subjected to
appropriate scrutiny.
Fortunately, licensees in the US
implemented a series of controls in the
late1980’s in response to discoveries of
fraudulent items, most of which were
commodities (Molded Case Circuit
Breakers (MCCB’s), pipe fittings,
fasteners and the like). These controls,
which are captured in NRC GL-89-02
(Actions to Improve the Detection of
Counterfeit and Fraudulently Marketed
Products 3/21/89) and Appendix C
of EPRI NP-6629 (Guidelines for the
Procurement and Receipt of Items
for Nuclear Power Plants), include
examining items and documentation for
known signs that they may be fraudulent
during receiving inspections.
Currently, utilities are implementing
a multi-tiered approach developed
through the collaborative effort of EPRI’s
members. The approach goes beyond
reliance on careful examination at receipt.
It involves implementing measures to
prevent, detect, and control CFI’s.
The nuclear industry in the US is
excellent at sharing information with
each other through operating experience.
This process has been in place since the
early 1980’s, and has served the industry
well in many areas. In the 1980’s the
NRC distributed a series of bulletins
and information notices on fraudulent
items, and the NRC continues to forward
pertinent information as they receive
it today. More recently, licensees have
been using existing processes for sharing
Nuclear Plant Journal, September-October 2013 NuclearPlantJournal.com
19
Integrated approach to mitigating
risks posed by counterfeit and
substandard items
.
