Counterfeit, Fraudulent, and Suspect Items (CFSI)

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The ENEC and ENEC Operations Counterfeit, Fraudulent, and Suspect Items (CFSI) Program is an integral part of the Integrated Management System and Quality Assurance Program. We are committed to implementing the highest standards of safety, security and quality and the robust CFSI prevention measures aim to prevent the entry and installation of CFSI items at the Barakah Nuclear Energy Plant. All CFSI requirements are outlined in the ENEC and ENEC Operations Quality Assurance Manual and are cascaded to implementing procedures.

DEFINITIONS

Counterfeit items - Items that are intentionally manufactured or altered to imitate a legitimate product without legal right to do so.

Fraudulent items - Items that are intentionally misrepresented to be something they are not. Fraudulent items include items provided with incorrect identification or falsified / inaccurate certification. Fraudulent items also include items sold by entities that have acquired the legal right to manufacture a specified quantity of an item (such as an integrated circuit),but produce a larger quantity than authorized and sell the overage as legitimate inventory.

Suspect items – Items which there is an indication by visual inspection, testing, or other information that it may not conform to established Government or industry-accepted specifications or national consensus standards.

Suppliers for the UAE Peaceful Nuclear Energy Program shall understand that the use of Counterfeit, Fraudulent and Suspect Items (CFSI) can affect Barakah NPP processes, operations and safety and they should be committed to prevent such items entering into the plant. Suppliers shall implement robust CFSI processes to ensure that services or products source through initial selection and approval of their supply chain and apply consistent monitoring of the supply chain to assure compliance with CFSI requirements.

The suppliers shall employ suitable qualified and experienced staff, which adopt a questioning attitude and is empowered to highlight any CFSI within the supply chain.

International References:

• NRC Regulatory Issue Summary 2015-08 – Oversight of Counterfeit, Fraudulent, And Suspect Items In The nuclear Industry.
• ANSI/ANS-3.2-2012 Managerial, Administrative and Quality Assurance Control for Operational Phase of Nuclear Power Plants.
• ASME NQA-1 1994 (with 1995 Addenda), Quality assurance Requirements for Nuclear Facility Application.
• EPRI NP-6629 "Guidelines for the procurement and receipt of items for nuclear power plant", May1990.
• EPRI TR-1019163 “Plant Support Engineering: Counterfeit, Fraudulent, and Substandard Items", October 2009.
• EPRI TR-1021439 "Plant Support Engineering: Counterfeit and Fraudulent items - A Self- Assessment checklist", October 2010
• IAEA-TECDOC-1169 "Managing Suspect and Counterfeit Items in the Nuclear Industry", August 2000.
• INPO Event Report, IER L4-12-86, Counterfeit Parts and Equipment Vulnerability
• NRC Regulatory Issue Summary 2015-08 Oversight of Counterfeit, Fraudulent, and Suspect Items in the Nuclear Industry
• US Department of Energy (DOE) G 414.1-3 Suspect/Counterfeit Items Guide for Use with 10 CFR 830 Subpart A, QA Requirements, and DOE O 414.1D, QA