The threat of counterfeit and fraudulent items (CFI) finding their way into nuclear plants is not new, but it has gained increased attention due to recent high-profile events such as those experienced by the nuclear industry in South Korea. Concern originally emerged in the late 1980s because of several incidents involving fraudulent commodity items such as piping components and refurbished molded-case circuit breakers being sold as new. These concerns prompted efforts by both the U.S. Nuclear Regulatory Commission and the U.S. commercial nuclear industry to improve the ability to detect fraudulent items. In the late 1980s, the NRC published Information Notice 89-70, Possible Indications of Misrepresented Vendor Products [1], and Generic Letter 89-02, Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products. [2] Information Notice 89-70 discussed factors that could be used by licensees to detect procurements involving fraudulent items, such as unusually low cost, unusually short delivery times, signs of refurbished parts, and other indications. Generic Letter 89-02 discussed elements of procurement programs that licensees should consider to enhance the ability to detect fraudulent items, such as engineering involvement in the procurement process, effective inspection and testing, and engineering-based dedication of commercial-grade items used in safety-related applications.
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