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NuclearPlantJournal.com Nuclear Plant Journal, September-October 2013
operating experience associated with
CFI’s.
This means that when suspected
fraudulent
items
are
identified,
the incident is reported and can be
systematically distributed and evaluated
so each licensee can take appropriate
action.
In addition, EPRI developed an
online database that has been “live” since
2011. At the current time, the database
is available to all commercial nuclear
licensees in the US as well as many
international utilities that operate nuclear
plants.
3.
What are the associated legal
issues when an equipment is labeled
as counterfeit incorrectly; especially,
because the information is published on
a website? What is done to avoid such a
situation?
One of the first points picked up
through our benchmarking was that there
are obvious risks in sharing this type
of information if it’s false. Even when
the information is accurate, the Origi-
nal Equipment Manufacturer/Original
Component Manufacturer (OEM/OCM)
might feel disclosure could be damaging
from a marketing perspective.
However, our team concluded that
creating a database was the right thing
to do. We do the best we can to address
both sides of the issue, safety and legal
concerns. The name of the EPRI database
is the Suspected Counterfeit/Fraudulent
Item Database (SCFI). Suspected is first
for a reason; the incidents reported involve
items suspected of being counterfeit or
fraudulent.
Our focus is on preventing suspect
items from making their way into nuclear
plants. Another point picked up during
our benchmarking is that it can be very
expensive and time consuming to conduct
a conclusive investigation for even a
single “well-faked” counterfeit. Such an
effort can literally involve a global search
and take years. Therefore, we agreed to
report incidents of suspected items.
We want to keep our resources
focused on keeping suspect items out
of the plants. Instead of attempting to
conduct a conclusive “law enforcement”
type of investigation into every incident,
EPRI’s process involves contacting the
OEM/OCM involved in each reported
incident. We share the report with the
manufacturer, and ask for any additional
information that may be helpful in
preventing future occurrences. So far,
all of the manufacturers contacted have
been cooperative. In several cases, it
turned out that the suspect items were
in fact authentic despite indication
that they might not be. In any case, we
add any information the manufacturer
provides to the report and then make it
available to our members. Hopefully this
will promote safety, allow members to
take appropriate precautions in a timely
manner, and minimize legal concerns.
4.
When was this counterfeit program
established and how many items
(electrical, electronic, mechanical, and
others) have been identified as counterfeit
in the database?
We started new research on CFI’s in
2008, and have published two technical
reports, a computer-based training
module, and set up our database.
EPRI’s database went live in August
of 2011. To date, about a dozen incidents
have been reported by members. None
were safety related.
5.
Does the EPRI database only cover
the commercial grade items or does it
include safety-related items as well?
The database is for any suspected
item, both safety and non-safety.
Fortunately, none of the identified items
were safety related.
6.
Have any control guidelines been
established to ensure that the utility
procurement executives do not entertain
the organizations, suspected of supplying
counterfeit items?
Each member uses the information
provided to put the necessary controls
in place. The type of controls may vary
based upon the particulars of the incident
and how it could impact each utility.
Suppliers can also be victims, so
it’s important to find the right corrective
action for each situation. This may require
working with our suppliers to prevent
recurrence. This is one of the reasons we
produced EPRI 1021493 (Plant Support
Engineering: Counterfeit and Fraudulent
Items), which is a self assessment
checklist suppliers (as well as licensees)
can use to identify vulnerabilities.
7.
Who are EPRI’s utility partners and
vendor partners in this effort?
Many EPRI members were involved
in the collaborative effort that produced
the original guidance document and
are continuing to work with EPRI on a
revision to the document. SCANA, Duke
Power (including legacy Duke and legacy
Progress Energy) and Dominion were
involved in a pilot benchmarking effort
that involved self-assessments (using the
self assessment guideline) and sharing
good practices. We are also working
closely with NEI, who has assembled an
industry team that is currently addressing
the NRC concerns identified in SECY
11-054 (An Agencywide Approach to
Counterfeit, Fraudulent, and Suspect
Items).
Computer Program
Dedication Questions
1.
What tools or software are used in
dedication methodology for computer
programs?
EPRI’s dedication methodology
involves a technical evaluation to
determine the applications, safety
classification, safety function(s), critical
characteristics, and acceptance methods
for a computer program.
2.
How is the dedication customized to
address computer programs for different
applications, such as accounting,
housekeeping,
radiation
database
tracking, maintenance, operation, and
multitude of different usages?
As the title indicates, EPRI 1025243
(Plant Engineering: Guideline for the Ac-
ceptance of Commercial-Grade Design
and Analysis Computer Programs Used
Counterfeit Items...
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