ML19129A446
| ML19129A446 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/2019 |
| From: | Shuttleworth A NRC/OI |
| To: | |
| Pasquale D | |
| References | |
| Download: ML19129A446 (19) | |
Text
THE 28 TH RAPIDConference & Technical ExhibitJUST ANOTHER TRIP TO THE BEACHClearwater, FLMay20-22, 2019Andy Shuttleworth, Director, Office of Investigations 2
JUST ANOTHER TRIP TO THE BEACH 3 4"I thought (the counterfeit market) was all about fake Louis Vuitton purses."Andy Shuttleworth National IPR Center 6https://www.iprcenter.gov/ Telephone:1-866-DHS-2-ICE 7ooo 7 8 10 11 12"-Systems,Structures,AndComponents(SSC) designsmustprovidethat the facility can be operated without undue risk to the health and safety of thepublic"JUST ANOTHER TRIP TO THEBEACH 14 15 16 17 16 19 ASSESSING THE RISK 18 1910 CFR 21 20Favorable criminal environment:
Favorable profit margins:Favorable market conditions:
UNDESIRABLE or ILLEGAL?
21 22Poor 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 A GLOBAL SUPPLY CHAIN PROBLEM 23 24https://www.oecd-nea.org/mdep/common-positions/cp-vicwg-04.pdfavailable for public useVendor Inspection Co-operation Working Group (VICWG)1.ASN -France2.CNSC -Canada3.KINS -South Korea4.NRA -Japan5.NNR -South Africa6.NRC -United States7.ONR -United Kingdom8.STUK -Finland 25https://www.oecd-nea.org/mdep/common-positions/cp-vicwg-04.pdfavailable for public use1.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 quarantiningof suspected items
)5.Enforcement (including response protocols & collaboration with Law Enforcement
)6.Effective CFSI training for all level of participation COLLABORATION 26 27 28Partnership with industry to fight CFSIGet ahead of the problem before it becomes a problemEducation and awareness at the right levels throughout industryWhat to do to prevent CFSI from entering the supply chainWhat to do when CFSI is detectedPartnership world-widePromoting increased CFSI reporting in IAEA/IRSNational Intellectual Property Rights Coordination CenterExchanging and sharing information and best practicesBuilding tools to connect industry with OEM and associations 29CFSI has nothing to do with LicenseeEncourage efforts beyond what is requiredexpose threats vs. hiding or ignoring themflush out bad actors, report their presence and keep them out of the equation eliminate risks from the supply chain wherever and whenever possiblequestion erratic or unusual component failuresrecognize reluctance, and public reporting vs public opinion CFSI-WHY OI?
30 31The NRC's Office of Investigation
- employs Federal Criminal Investigators/Special Agents from:DHS, FBI, DEA, ATF, NCIS, Postal Inspections Service, Secret Service, and Offices of Inspectors Generalworks closely with Europol, Interpol, DOS & otherscontinues to conduct high quality investigationsfollows Attorney General and Department of Justice Guidelines regarding investigative standardsensures that stakeholders are fully informed of the conclusions of independent investigations 32The OI is committedto combatting the introduction of counterfeit parts into the nuclear supply chain through strategic partnershipswith internal and external stakeholders, both domestically and globally 33Assist in developing a Common Practice for responding to CFSI and aberrant behavior between international regulatorsAssist with confirmation evaluations of suspect counterfeit or fraudulent incidents Establishing and training dedicated CFSI response teamsCollaborate with appropriate Law Enforcement AgenciesInformation deconflictionCollaborate with OEMs and Federal Agencies to issue product announcement of high CFSI risk componentsRouting identified occurrences of Non-10 CFR 21 defectsDataNet -Using data analytics as a Proactive Anti-CFSI toolAssist with performance of "due diligence" Addressing "reasonable assurance" in a rapidly evolving supply chain Direct access to OEMs, Trade Associations , and International Anti-counterfeiting CoalitionsAssist with developing supply chain safety culture attributes (including "insider threats")Facilitate knowledge transferLessons learnedImproved receipt inspectionsTrain the TrainerNEED NORE INFORMATION?
34 35https://www.nrc.gov/about-nrc/cfsi.htmlFOR MORE INFORMATION-36https://www.nrc.gov/about-nrc/cfsi.htmlDan Pasquale, Office of InvestigationsSr. Reactor Systems Engineer(301) 415-2498Daniel.Pasquale@nrc.gov 37