ML19030B859
| ML19030B859 | |
| Person / Time | |
|---|---|
| Issue date: | 02/12/2019 |
| From: | Shuttleworth E NRC/OI |
| To: | |
| Pasquale D | |
| References | |
| Download: ML19030B859 (34) | |
Text
JUST ANOTHER TRIP TO THE BEACH February 12-14, 2019 EPRI JUTG Fort Worth, TX Andy Shuttleworth, Director, Office of Investigations
2 The OI Mission Just Another Trip to the Beach Assessing the Risk Undesirable or Illegal?
Community Watch A Global Supply Chain Problem Need More Information?
3 THE OI MISSION 4
Responsibilities outlined in Title 10 of the CFR, Part 1.36, Office of Investigations
- Conduct investigations of allegations of wrongdoing
- Maintain current awareness of inquiries and inspections by other NRC offices
- Make appropriate referrals to the Department of Justice
- Liaise with other agencies and organizations, both domestic and international, to ensure the timely exchange of information of mutual interest
5 I thought (the counterfeit market) was all about fake Louis Vuitton purses.
Andy Shuttleworth National IPR Center
Telephone: 1-866-DHS-2-ICE
7
- Generates nearly $1.5 trillion in illicit proceeds every year
- Over 80% of all counterfeit items seized coming into the U.S. originated from one country
- Three big drivers:
o cyber commerce, o express consignment delivery, o just-in-time inventory
- It goes far beyond what we think we know
8 9
10 11
- Counterfeit components are prevalent in all areas of industrial technology, counterfeiting is a criminal activity and in these instances industry is the victim.
- Costs associated with counterfeits go beyond the basic fraud and cost industry in lost production, costly man hours, and repairs.
- Potential safety hazards for employees and the general public as well, in extreme cases could pose a risk to national security.
- Supply chain integrity is the goal, but effective partnership with industry is the key.
12 Systems, Structures, And Components (SSC) designs must provide that the facility can be operated without undue risk to the health and safety of the public
13
- to the best possible extent provided given the situations circumstances, the author is reasonably sure that his conclusions are free from material misstatement (but there might be some misstatements that go undetected)
- acknowledgment that it is not possible to assert absolutely and certainly that an event will (or will not) occur
14 JUST ANOTHER TRIP TO THE BEACH 15 16 17 18 19 20 ASSESSING THE RISK 21 An acceptance process undertaken to provide that a commercial grade item to be used as a basic component will perform its intended safety function and, in this respect, is deemed equivalent to an item designed and manufactured under a 10 CFR Part 50, appendix B, quality assurance program.
22 Favorable criminal environment: Favorable profit margins:
- lack of reporting
- high profit potential
- little fear of prosecution
- low capital and labor costs
- low fines and sentences upon
- access to sub-suppliers conviction
- easily distributed via the internet
- unprecedented anonymity
- no research & development costs
- may involve alternate illicit
- no advertising costs activities Favorable market conditions:
- obsolescence Aging operating units
- global supply chain 58 nuclear plants under construction worldwide
- diminishing suppliers (10 CFR 50, Appendix B) More CGDs
- new norms high in-service failures
23 UNDESIRABLE or ILLEGAL?
24 Poor performance by a vendor resulting in a nonconformance, while undesirable, can be managed by effective customer oversight.
Intentionally misrepresenting equipment, parts or materials is illegal and must be dealt with appropriately
25 The NRCs Safety Culture policy statement, applies to all licensees, certificate holders, permit holders, authorization holders, holders of quality assurance program approvals, vendors and suppliers of safety-related components, and applicants for a license, certificate, permit, authorization, or quality NUREG/BR-0500 assurance program approval subject to NRC
- ML15062A478 authority.
- NUREG/BR-0500, Rev. 3
26 COMMUNITY WATCH 27
- CFSI has nothing to do with Licensee
- Encourage reporting beyond what is required o Hiding or ignoring the threat vs exposing those who are a threat o Flush out who is doing it, where it is coming from o Keeping bad actors from reestablishing
- Recognize reluctance, public reporting vs public opinion
28 A GLOBAL SUPPLY CHAIN PROBLEM 29 Multinational Design Evaluation Programme Common Position CP-VICWG-04 10/23/2018 Vendor Inspection Co-operation Working Group (VICWG)
- 1. ASN - France
- 2. CNSC - Canada
- 3. KINS - South Korea
- 4. NRA - Japan
- 5. NNR - South Africa
- 6. NRC - United States
- 7. ONR - United Kingdom
- 8. STUK - Finland https://www.oecd-nea.org/mdep/common-positions/cp-vicwg-04.pdf available for public use
30 CP-VICWG-04 General Topics:
- 1. Information & notification in the case of irregularities (including safety culture )
- 2. Testing and materials (including sharing CFSI information)
- 3. Inspection of licensees, suppliers, and external parties (including identification of at-risk procurements)
- 4. Control of commercial products used in safety-related applications (including quarantining of suspected items)
- 5. Enforcement (including response protocols & collaboration with Law Enforcement)
- 6. Effective CFSI training for all level of participation https://www.oecd-nea.org/mdep/common-positions/cp-vicwg-04.pdf available for public use
31 Partnering with industry to fight CFSI
- Get ahead of the problem before it becomes a problem
- Education and awareness at the right levels throughout industry
- What to do to prevent CFSI from entering the supply chain
- What to do when CFSI is detected Partnership world-wide
- National Intellectual Property Rights Coordination Center
- Exchanging and sharing information and best practices
- Building tools to connect industry with OEM and associations
32 NEED NORE INFORMATION?
FOR MORE INFORMATION 33 https://www.nrc.gov/about-nrc/cfsi.html Dan Pasquale, Office of Investigations Sr. Reactor Systems Engineer (301) 415-2498 Daniel.Pasquale@nrc.gov
34