doe suspect/counterfeit item
TRANSCRIPT
Vienna, Austria September 9, 2014
Duli C. Agarwal, PE Office of Quality Assurance (AU-33)
U.S. Department of Energy Chair, NQA-1 Subcommittee on Applications
DOE Nuclear Suspect/Counterfeit Item Framework
DOE Suspect/Counterfeit Item (S/CI) Framework Overview
• DOE Organization and Mission
• DOE Nuclear Facility Portfolio
• DOE Quality Assurance (QA) Requirements
• DOE Counterfeit Item Prevention Program
• DOE issues and challenges related to counterfeit item prevention
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U.S. Department of Energy
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DOE Mission
SCIENCE & INNOVATION
ENERGY NUCLEAR SAFETY & SECURITY
MANAGEMENT &
OPERATIONAL EXCELLENCE
Catalyze the timely, material, and efficient transformation of the Nation’s energy system and secure U.S. leadership in clean energy technologies.
Maintain a vibrant U.S. effort in science and engineering as a cornerstone of our economic prosperity with clear leadership in strategic areas.
Enhance nuclear security through defense, nonproliferation, and environmental efforts.
Establish an operational and adaptable framework that combines the best wisdom of all Department stakeholders to maximize mission success.
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Environmental Management (EM)
~108 facilities ~$20 billion new projects
NNSA
~72 facilities
~$15–20 billion new projects
Chief of Nuclear Safety
Chief of Defense Nuclear Safety
Nuclear Energy (NE) ~20 facilities
Chief of Nuclear Safety
Science ~18 facilities
Nuclear Facility Portfolio
Under Secretary for
Energy & Science
Under Secretary for
Nuclear Security
Under Secretary for
Management & Performance
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• Fuel Cycle R&D
• Nuclear Fuel Disposition R&D
• Uranium Management & Policy
Deputy Asst. Secretary for
Science and Technology Innovation
Nuclear Energy (NE) R&D Portfolio
Assistant Secretary for
Nuclear Energy
Deputy Asst. Secretary for
Nuclear Reactor Technologies
Deputy Asst. Secretary for
Fuel Cycle Technologies
• Advanced Simulation
• Innovative Nuclear Research
• LWR Technologies
• Advanced Reactor Technologies
• Space & Defense
Power Systems
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• 10 CFR Part 830, Nuclear Safety Management (QA & Safety Basis)
– 10 QA Criteria
– Use voluntary consensus standards
– Integrate the quality assurance criteria with the safety management system
• DOE Order 414.1D, Quality Assurance (Nuclear & Non-Nuclear Facilities)
– 10 QA Criteria
– Suspect/Counterfeit Items (S/CI)
– Nuclear Safety Software
– Use of National and International Standards
• DOE G 414.1-2B, Quality Assurance Program Guide
– Provides enhanced understanding on the 10 QA Criteria, and Graded Approach/Application
Quality Assurance Regulatory Framework
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S/CI Requirements
• DOE Order 414.1D, Attachment 3, Suspect/Counterfeit Items Prevention
– Program, responsibilities, inspection, control
– Once adopted, civil/criminal/contract penalties for noncompliance
• DOE O 232.2, Occurrence Reporting and Processing of Operations Information
• DOE Awareness Training Manual, 2007
• DOE Order 221.1A, Reporting Fraud Waste & Abuse to the Office of the Inspector General
• IAEA-TECDOC-1169, Managing suspect and counterfeit items in the nuclear industry (This is guidance and not a requirement)
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Suspect/Counterfeit Item Framework
Pretreatment Facility
Analytical Laboratory
Low-Activity Waste Facility
High-Level Waste
Balance of Facilities
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Why is S/CI Prevention Important to DOE?
Waste Treatment Plant – currently under construction
Mixes low-activity rad-waste in glass
70% Construction Complete
Low-Activity Waste Facility exterior
Low-Activity Waste carbon bed adsorber
Low-Activity Waste transfer tunnel
Overhead pipe racks for steam and glass formers
200-ton Low-Activity Waste melter
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Low-Activity Waste Vitrification Facility
• Prevention and detection of Suspect/Counterfeit Items in the DOE supply chain. In 2012, DOE formed S/CI Focus Group to address new S/CI risks, tactics, and sources.
• Reporting of S/CI. U.S. Federal Agencies formed a task group to determine if revisions are needed to address S/CI.
• Implementation of the Commercial Grade Dedication Process requirements. The Quality Council will work with EFCOG to develop a methodology with examples (15–20 examples, i.e., diesel generator).
• Purchasing Practices. National Defense Authorization Act (NDAA) revision emphasizes purchase from Original Component Manufactures or authorized distributors.
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S/CI Issues and Challenges
• DOE established requirements for preventing counterfeit items in 2004. The S/CI Focus Group is working to identify improvements and avoid complacency to address new S/CI risks.
• Existing programs may need to adapt the following:
Expand focus: mechanical and hardware to electronics
New Government-wide initiatives
FAR Part 46 proposal to expand reporting of nonconforming items to include S/CI and require higher-level contract quality requirements.
NDAA 2012/13
Update DOE training
New standards and technologies
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S/CI Initiatives for Improvement
External S/CI Efforts Impacting DOE
2011
*TPD – Task Planning Document
2013
Documented history of DOE’s S/CI awareness and initiatives
≈1989–2010 NDAA 2012 is enacted
December 2011
DOE Quality Council forms S/CI Focus Group
January 2012
Quality Council approves S/CI
Prevention TPD*
April 2012
FAR Case 2012-032
August 2012
FAR Case 2013-002
October 2012
1989
The White House forms an interagency S/CI Initiative
2011
HSS Quality Council
2012 JAN
DEC APR OCT AUG
JAN
2014
IAEA TECDOC-1169
Revision
June 2014
NDAA 2013 is enacted
January 2013
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Example of S/CI at a DOE site
• Reporting Criteria: 4C(3) – Discovery of any defective item or material, other than a suspect/counterfeit item or material, in any application whose failure could result in a loss of safety function, or present a hazard to public or worker health and safety. (DOE O 232.2 requirement)
• The scaffold tube end fitting failed internal to the tubing and showed no external signs of damage, cracking, or corrosion. The metallic face of the break was significantly discolored over the vast majority of the surface. The pole was stenciled in black as being made in China for STEPUP Scaffolding. Random scaffold poles with similar markings were cut to expose the end fitting and several of the castings were found to be out of round and/or cracked.
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Example S/CI ORPS Report
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Example S/CI ORPS Report
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Example S/CI ORPS Report
NQA Committee S/CI Projects for NQA-1
• The NQA Committee approved a project to develop requirements for the prevention of suspect, counterfeit, and fraudulent items.
• The Part III guidance inclusion is expected to be published in the NQA-1 2014 edition
• The committee is also looking to include Part II requirements into NQA-1, but it is in the preliminary stages.
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• DOE has a complex and wide ranging mission.
• DOE has a large Nuclear Facility Portfolio, including R&D facilities.
• DOE has requirements enforcing S/CI prevention in the supply chain.
• There are continuous efforts to improve through the S/CI prevention program by participating with consensus standard bodies such as ASME, IAEA, and other U.S. Federal agencies, such as NRC, etc.
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Summary
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