Nuclear Services / Engineering Services

Preventing Intrusion of Counterfeit,

Fraudulent and Suspect Items into the
Nuclear Supply Chain
Background
For many years, the nuclear industry
regulators have been concerned about
preventing the intrusion of counterfeit,
fraudulent and suspect items (CFSI) into
the nuclear supply chain. This issue is
not receding, and it is incumbent on all
stakeholders, including suppliers, to stay
current on this evolving issue and to provide
appropriate processes in order to prevent
introduction of CFSI into the nuclear supply
chain.

GL 89-02 puts forth three characteristics of

procurement and dedication programs that are
effective in detecting counterfeit or fraudulently
marked products. The three characteristics are:

1. The involvement of engineering staff in the

procurement and product acceptance process
2. Effective source inspection, receipt inspection
and testing programs
3. Thorough engineering-based programs to
review and test the suitability of commercialgrade products for use in safety-related
applications

Description
Westinghouse processes and initiatives regarding
CFSI are in alignment with pertinent regulatory
guidelines, which include:
yy The 1989 U.S. Nuclear Regulatory Commission
(NRC) Generic Letter (GL) 89-02, Actions
to Improve the Detection of Counterfeit and
Fraudulently Marked Products
yy The 2008 NRC Information Notice 2008-04,
Counterfeit Parts Supplied to Nuclear Power
Plants
yy The 2011 NRC SECY-11-0154, An Agencywide
Approach to Counterfeit, Fraudulent and
Suspect Items

NLP 7300 cards, original (back)

and redesigned (front)

June 2013

NS-ES-0250

2014 Westinghouse Electric Company LLC. All Rights Reserved

Benefits

Processes and Initiatives

Position

Westinghouse implements processes and

initiatives, including those to identify and prevent
nonconformances, increase organizational learning,
and minimize the frequency and severity of events, all
of which help detect and prevent CFSI. Westinghouse
implements business-specific initiatives to detect and
prevent CFSI.

Westinghouse believes that a robust quality assurance

program and processes that address the three
characteristics identified in GL 89-02 are effective
in detecting and preventing CFSI. To this point, the
Westinghouse Quality Management System and lowertier procedures align with the three characteristics
identified in GL 89-02.

The involvement of
engineering staff in the
procurement and product
acceptance process

Effective source inspection,

receipt inspection and
testing programs

Thorough Engineeringbased programs for review,

testing and dedication of
commercial-grade products
for suitability for use in
safety-related applications

Suspect and Counterfeit Items

Supplier Qualification
and Assessment

Procedure for Control

of Purchased Items
and Services

Quality Oversight at
Supplier Facilities
Receipt Inspection

Procedure for
Dedication of
Commercial-grade
Items

Test Control
Certificate of Conformance

Westinghouse Quality Assurance procedures and alignment with GL 89-02

Receipt Inspection
Process

QC Inspector
Training

Empirical testing of
products / material and
use of PMI (positive
material identification)
techniques

Inspectors trained to
identify counterfeit parts

XRF (X-Ray
Fluorescence) analysis
and Sim Scope

Training materials
incorporate guidance
from NRC-SECY-11-0154,
EPRI 1021493 and
EPRI 1019163

Design
Engineering
Knowledge

Detailed design
knowledge by virtue of
Westinghouse OEM
design ownership

Initiatives to detect and prevent CFSI