March 22, 2002

Mr. Ronald A. Milner, Chief Operating Officer

Office of Civilian Radioactive Waste Management

U. S. Department of Energy

1000 Independence Avenue, SW

Washington, DC 20585

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSIONíS OBSERVATION AUDIT

REPORT NO. OAR-02-04, ìOBSERVATION AUDIT OF THE BECHTEL SAIC

COMPANY, LLC, AUDIT NO. BSC-SA-02-009 OF SENIOR FLEXIONICS,

INCORPORATEDî 

Dear Mr. Milner:

I am transmitting the U.S. Nuclear Regulatory Commissionís (NRCís) Observation Audit Report

(No. OAR-02-04). It is on the U.S. Department of Energyís (DOEís) Management and

Operating Contractorís (M&Oís) Quality Assurance (QA) audit of Senior Flexionics,

Incorporated, Pathway Division (SFIPD). Specifically, it was DOEís Office of Civilian

Radioactive Waste Managementís M&Oís contractor Bechtel SAIC Company, LLC (BSC), that

performed the audit of SFIPD. This audit was conducted on February 20-21, 2002, at SFIPD

facilities in New Braunfels, Texas.

The purpose of this audit was to evaluate those elements of SFIPDís QA Program where BSC 

had recommended changes because of problems identified during a previous BSC survey,

BSC-SFE-01-008. 

The scope of the audit was to evaluate if SFIPD had effectively implemented BSCís

recommended changes in six elements of its QA Program - - (1) Control of Purchased Items

and Services; (2) Control of Special Processes; (3) Test Control; (4) Control of Measuring and

Test Equipment; (5) Corrective Action; and (6) QA Records, and to review the work performed

on the welded rings.

The NRC observers (hereafter observers) determined that this audit was effective in identifying

potential deficiencies and recommending improvements for SFIPD activities reviewed. During

the conduct of the audit, both the BSC audit team (hereafter audit team) and the observers

reviewed applicable documents, procedures, and activities within the auditís scope, and

observed one completed set (two welded rings) of setup specimens that had been fabricated

for test setup and trial welding.

The audit team identified one deficiency in the area of nonconformance control. The staff

believes that this BSC audit was well-planned, thorough, and adequately evaluated the actions

that SFIPD took to improve its QA activities.
R. Milner -2-

The observers agreed with the audit teamís conclusions, findings, and recommendations

presented at the audit exit. The staff will continue to interface with OCRWM and follow the

progress that SFIPD is making to address the issues identified during this audit.

A written response to this letter and the enclosed report is not required. If you have any

questions, please contact Kamal Naidu of my staff at (301) 415-5020.

Sincerely,

/RA/

Janet Schlueter, Chief

High-Level Waste Branch

Division of Waste Management

Office of Nuclear Material Safety

 and Safeguards

Enclosure: NRC Observation Audit Report 

No. OAR-02-04, ìObservation Audit 

of the Bechtel SAIC Company, LLC, 

Audit No. BSC-SA-02-009 of Senior Flexionics, Incorporated.î

cc: See attached list.
R. Milner -2-

The observers agreed with the audit teamís conclusions, findings, and recommendations

presented at the audit exit. The staff will continue to interface with OCRWM and follow the

progress that SFIPD is making to address the issues identified during this audit.

A written response to this letter and the enclosed report is not required. If you have any

questions, please contact Kamal Naidu of my staff at (301) 415-5020.

Sincerely,

/RA/

Janet Schlueter, Chief

High-Level Waste Branch

Division of Waste Management

Office of Nuclear Material Safety

 and Safeguards

Enclosure: NRC Observation Audit Report 

No. OAR-02-04, ìObservation Audit 

of the Bechtel SAIC Company, LLC, 

Audit No. BSC-SA-02-009 of Senior Flexionics, Incorporated.î

cc: See attached list.

DISTRIBUTION:

FILE CENTER HLWB r/f DWM r/f ACNW PUBLIC OSRs

LSN CNWRA CWReamer JSchleuter KStablein DBrooks

TEssig SWastler BSpitzberg WMaier, RIV LChandler DDambly

MYoung DHiggs LCampbell BMabrito TTrbovich TCarter

RBrient WSmith JParrott TAhn

DOCUMENT NAME: S:\DWM\HLWB\KRN\Flexoni6.wpd

ADAMS ACCESSION NUMBER: ML020850298

OFFICE HLWB Tech Ed HLWB HLWB

NAME K. Naidu E. Kraus K. Stablein J. Schlueter

DATE 03/12/02 03/05/02 03/14/02 03/22/02

 OFFICIAL RECORD COPY 

ACNW: YES X NO Delete file after distribution: Yes No

1) This document should be made available to the PUBLIC.

2) This document is related to the HLW program. It should be placed in the LSS.

This document is Non-Sensitive
Letter to R. Milner from J. Schlueter dated March 22, 2002 

cc:

R. Loux, State of Nevada R. Massey, Lander County, NV

S. Frishman, State of Nevada L. Stark, Lincoln County, NV

L. Barrett, DOE/Washington, DC M. Baughman, Lincoln County, NV

A. Brownstein, DOE/Washington, DC A. Funk, Mineral County, NV

S. Hanauer, DOE/Washington, DC J. Shankle, Mineral County, NV

C. Einberg, DOE/Washington, DC L. Bradshaw, Nye County, NV

J. Carlson, DOE/Washington, DC M. Murphy, Nye County, NV

N. Slater, DOE/Washington, DC J. McKnight, Nye County, NV

A. Gil, YMPO D. Weigel, GAO

R. Dyer, YMPO W. Barnard, NWTRB

S. Brocoum, YMPO R. Holden, NCAI

R. Davis, YMPO A. Collins, NIEC

S. Mellington, YMPO R. Arnold, Pahrump Paiute Tribe

C. Hanlon, YMPO J. Larson, White Pine County

T. Gunter, YMPO R. Clark, EPA

K. Hess, BSC F. Marcinowski, EPA

D. Krisha, BSC R. Anderson, NEI

S. Cereghina, BSC R. McCullum, NEI

N. Williams, BSC S. Kraft, NEI

M. Voegele, BSC/SAIC J. Kessler, EPRI

D. Beckman, BSC/B&A D. Duncan, USGS

B. Price, Nevada Legislative Committee R. Craig, USGS

J. Meder, Nevada Legislative Counsel Bureau W. Booth, Engineering Svcs, LTD

I. Navis, Clark County, NV L. Lehman, T-REG, Inc

E. von Tiesenhausen, Clark County, NV S. Echols

A. Kalt, Churchill County, NV N. Rice, NV Congressional Delegation

G. McCorkell, Esmeralda County, NV T. Story, NV Congressional Delegation

L. Fiorenzi, Eureka County, NV J. Reynoldson, NV Congressional Delegation

A. Johnson, Eureka County, NV S. Joya, NV Congressional Delegation

A. Remus, Inyo County, CA J. Pegues, City of Las Vegas, NV
M. Yarbro, Lander County, NV R. Bahe, Benton Paiute Indian Tribe

I. Zabarte, W.S.N.C. C. Bradley, Kaibab Band of Southern Paiutes

C. Anderson, Las Vegas Paiute Tribe R. Joseph, Lone Pine Paiute-Shoshone Tribe

J. Birchim, Yomba Shoshone Tribe L. Tom, Paiute Indian Tribes of Utah

L. Jackson, Timbisha Shoshone Tribe E. Smith, Chemehuevi Indian Tribe

C. Meyers, Moapa Paiute Indian Tribe J. Charles, Ely Shoshone Tribe

V. Miller, Fort Independence Indian Tribe D. Crawford, Inter-Tribal Council of Nevada

A. Bacock, Big Pine Paiute Tribe of

 the Owens Valley

H. Blackeye, Jr., Duckwater Shoshone Tribe

R. Quintero, Inter-Tribal Council of Nevada

(Chairman, Walker River Paiute Tribe)

D. Eddy, Jr. Colorado River Indian Tribes

M. Bengochia, Bishop Paiute Indian Tribe J. Leeds, Las Vegas Indian Center

J. Egan, Egan & Associates, PLLC W. Briggs, Ross, Dixon & Bell
-1-

U.S. NUCLEAR REGULATORY COMMISSION

OBSERVATION AUDIT REPORT NO. OAR-02-04

ìOBSERVATION AUDIT OF THE

BECHTEL SAIC COMPANY, LLC

AUDIT NO. BSC-SA-02-009 OF SENIOR FLEXIONICS, INCORPORATEDî

 /RA/ 03/12/02 /RA/ 03/14/02 

Kamalakar R. Naidu Bruce Mabrito

Projects and Engineering Section Center for Nuclear Waste Regulatory 

High-Level Waste Branch Analyses

Division of Waste Management

Reviewed and Approved by:

 /RA/ 03/14/02 

N. King Stablein, Chief

Projects and Engineering Section

High-Level Waste Branch

Division of Waste Management
-2-

1.0 INTRODUCTION

1.1 Senior Flexionics, Incorporated (Background)

The current ìStatement of Work Agreementî between the U.S. Department of Energy (DOE)

Office of Civilian Radioactive Waste Management (OCRWM), Management and Operating

Contractor (M&O), and Senior Flexionics, Incorporated, Pathway Division (SFIPD), is Technical

Services Statement of Work, Revision 1, dated October 22, 2002. The scope of work, under

the current statement of work, is for SFIPD to provide all materials, labor, fabrication, and

nondestructive examination (NDE) resources necessary to fabricate, test, and record data

related to welding samples simulating the waste package closure weld. SFIPD will fabricate 18

rings similar to the ones that will be used to seal-weld the spent fuel containers. SFIPD will

fabricate two trial-specimen welded rings, during which all manufacturing process methods will

be finalized. SFIPD will perform NDE on each specimen, including weld-flaw information for

each specimen; take measurements of surface residual stresses; and perform metallography.

Production of the weld-flaw maps will require extensive metallography and is included in the

scope of the work. PCI, Illinois, a subcontractor to SFIPD, will bring its automatic welding

machine from Illinois to New Braunfels, Texas, and install it at SFIPD, to weld the final 16 rings,

under the SFIPD Quality Assurance Program (QAP). SFIPD will either perform all the NDEs, or

subcontract some of them to an approved vendor.

1.2 Performance of the Audit

Staffs from the U.S. Nuclear Regulatory Commission (NRC), Division of Waste Management,

and the Center for Nuclear Waste Regulatory Analyses (CNWRA) observed the M&O, Bechtel

SAIC Company (BSC), audit BSC-SA-02-009 of activities regarding the implementation of the

SFIPD Quality Assurance Manual (QAM). This audit was conducted on February 20-21, 2002,

at SFIPD facilities in New Braunfels, Texas. The purpose of this audit was to evaluate the

effectiveness of the implementation of SFIPDís QAM, and to determine if applicable

requirements of the OCRWM QAP Requirements and Description (QARD), Revision 10, were

being met. The scope of the audit included evaluating the implementation of the

recommendations made in Supplier Survey BSC-SFE-01-008.

The NRC observersí (hereafter observersí) objective was to assess whether BSC Quality

Assurance (QA), Product Quality Engineering/Supplier Audits and Evaluation Sectionís, audit

team (hereafter audit team) and SFIPD were properly implementing the QA requirements

contained in Subpart G, ìQuality Assurance,î to Part 63, of Title 10 of the U.S. Code of Federal

Regulations (10 CFR Part 63) and the provisions contained in the QARD. This report presents

the observersí determination of the effectiveness of the BSC audit and whether SFIPD

implemented adequate QARD and QAM controls in the audited areas.

2.0 MANAGEMENT SUMMARY

Within the areas evaluated, the audit team identified one deficiency. This deficiency does not

appear to impact the quality and technical adequacy of the SFIPD products being supplied to

BSC. The deficiency had two examples. In one example, SFIPD closed a nonconformance

where the disposition was to use rejected material as use-as-is without convening a Material
-3-

Review Board (MRB), as required by Section 8 of SFIPDís QAM. In another instance, SFIPD

closed a nonconformance where the disposition was to repair the rejected material; this was

also closed without convening an MRB. During the previous survey, BSC identified a similar

instance in which the disposition in a nonconformance was use-as-is, and SFPID closed it

without convening an MRB. The observers determined that BSC Audit No. BSC-SA-02-009

was well-planned and effectively executed. The audit team members were independent of the

activities they audited and were knowledgeable regarding the QA and technical disciplines

within the scope of the audit. The audit team concluded that the QARD and QAM had been

satisfactorily implemented in the areas evaluated. The observers agreed with the audit teamís

conclusions, findings, and recommendations presented at the audit exit. The staff will continue

to interface with OCRWM and follow the progress that SFIPD is making to address the issues

identified during this audit.

3.0 AUDIT PARTICIPANTS

3.1 Observers

Kamalakar R. Naidu Team Leader NRC

Bruce Mabrito QA Observer Center for Nuclear Waste

Regulatory Analyses

3.2 BSC Audit Team

Robert F. Harstern Audit Team Leader

Daniel A. Klimas Audit Team Member

3.3 Bechtel SAIC, LLC, Yucca Mountain Project

Jerry Cougar Manager, Engineering and Fabrication

Roxie VanDillen Quality Compliance

3.4 SFIPD

Terry J. OíConnor QA Director

Steve Andrews Project Coordinator

Larry Verner Senior Engineer, Nuclear

Gene Woefel Quality Control Manager

Steve Woolery Chief Inspector, Quality Control

3.5 Contract Inspection Services

Curtis Wendler Authorized Inspector

4.0 REVIEW OF THE AUDIT AND AUDITED ORGANIZATION

The BSC audit of SFIPD was conducted in accordance with OCRWM Procedures AP 18.2Q,

ìInternal Audit Program,î and AP 16.1Q, ìManagement of Conditions Adverse to Quality.î The

NRC staffís observation was based on NRC Manual Chapter 2410, ìConduct of Observation

Audits,î dated July 12, 2000.
-4-

4.1 Audit Scope 

The scope of the audit was to evaluate how effective the SFIPD QAP was in specific areas (as

delineated in the BSC Technical Services Statement of Work, Revision 1, dated October 22,

2001) regarding implementation of BSCís recommendations in those six elements of the SFIPD

QAP wherein BSC had identified concerns during the previous survey - BSC-SFE-01-08. 

These elements included; 1) Control of Purchased Items and Services; 2) Control of Special

Processes; 3) Test Control; 4) Control of Measuring and Test Equipment; 5)Corrective Action;

and 6) QA records. The audit also examined other areas related to the fabrication of the

welded rings, and associated operating procedures.

4.2 Audit Conduct and Timing

The audit was performed effectively and the audit team demonstrated a sound knowledge of

the applicable SFIPD program and procedures. BSC developed an audit checklist using the

ìTechnical Services Statement of Work for Waste Package Weld Flaw Analysis,î Revision 1,

the QARD, and the SFIPD QAM. The audit team members conducted thorough interviews;

they challenged responses when appropriate; and they effectively employed their audit

checklist. The observers concluded that the timing of the audit was appropriate because the

audit team was able to observe one welded ring sample that SFIPD had completed. The audit

team and the observers caucused at the end of each day. Meetings between the audit team

and SFIPD management, with the observers present, were held each morning, to discuss the

current audit status and preliminary findings.

4.3 Audit Team Qualification and Independence

The qualifications of the audit team were verified during previous reviews, and determined to be 

in accordance with the requirements of DOE Procedure AP 18.1Q, ìAuditor Qualification.î The

observers concluded that the audit team members had the necessary expertise to perform the

audit and were qualified to audit the SFIPD. The observers also concluded that the audit team

members had sufficient authority and organizational freedom to make the audit process

meaningful and effective.

4.4 Examination of QA and Administrative Requirements

The observation team determined that audit activities were appropriately conducted in

accordance with the OCRWM QA Audit Plan for Audit No. BSC-SA-02-009. The auditors

reviewed selected project documents identified in the audit plan and employed a detailed

checklist as the basis for their reviews. The audit team also examined related project technical

documentation to verify the accuracy of source material and the status of data qualification

activities. The auditors conducted interviews with personnel with appropriate levels of

knowledge who were directly responsible for the development of the travelers for the welded

rings, and for associated quality requirements. During the conduct of the these interviews, the

auditors effectively used the audit checklist to focus the inquiries on areas of technical concern. 

The audit team also gave the NRC observers adequate opportunities to provide comments, and

to seek clarification on technical issues. 
-5-

The NRC observers determined that the programmatic elements of DOE QA Procedure (QAP)

18.2Q, Revision 0, ìInternal audit Program,î were appropriately implemented by the audit team. 

Specifically, the well-developed planning and implementation aspects of this audit were

demonstrated during the conduct of the audit entrance meeting; coordination and

communication between team members; the development of preliminary audit findings; and the

clear articulation of these findings.

4.5 Examination of the QA Elements

Before begining the audit, SFIPD officials accompanied the audit team and observers on a tour

of their facilities. The NRC staff observed the audit team conducting detailed checks of the

technical adequacy of the SFIPD activities related to the fabrication of the welded rings. The

audit team used a combination of technical-issue probing and procedural-compliance checks

and verifications to thoroughly consider the technical adequacy of the weld procedures, NDE,

and information contained in the SFIPD travelers. 

4.5.1 Procurement Control

The auditors reviewed SFIPD purchase orders (POs) to key vendors for the fabrication of the

welded rings, to determine if appropriate QA requirements contained in the ìTechnical Services

Statement of Work for Waste Package Weld Flaw Analysisî were incorporated in them, and if

the QA requirements of the SFIPD were followed in the preparation. The QA Directorís

signature on the POs indicated his review and approval. The auditors reviewed other POs to

determine if SFIPD used only those vendors listed on its Approved Vendors List (AVL). The

auditors selected a few vendors and verified if SFIPD followed its QAP requirements to qualify

them to be placed on the AVL, and if there was adequate documentation to support placement

of those vendors on the AVL. The auditors did not identify any adverse findings in this area.

The observers agreed with the audit team findings in this area.

4.5.2 Identification and Control of Items and Materials

When SFIPD receives a shipment of procured items, its receipt inspectors inspect the shipment

for shipping damage, complete a receipt inspection form, and identify the material with a unique

alpha numerical number that is used to trace the material. In answer to an auditorís query,

SFIPD replied that, in instances when a piece of material is cut off, then the unique number is

transcribed to the cut piece. During the tour of the SFIPD facilities, the audit team observed

that all components in the shop were identified with a unique alpha numerical number. The

auditors verified that the identification numbers on the welded rings and those documented in

the travelers were identical.

SPID prepared ìJob Travelers,î in which it documents the sequence of the various

manufacturing steps. The job travelers identified mandatory hold points for in-process

inspections and NDE, in-process, as well as final, inspections; and referenced relevant 

drawings, and weld procedure specifications, as necessary. The auditors verified that all the

steps in the traveler, specifically in-process inspections, for the welded rings, were followed

sequentially, as indicated by the sign-off dates.
-6-

The observers agreed with the audit team findings in this area.

4.5.3 Control of Measuring and Test Equipment (MT&E))

The auditors reviewed the actions SFIPD took to implement the BSC recommendation,

regarding calibration, during the last survey. Specifically, BSC identified that, contrary to

Section 9A of the SFIPD QAM, the stickers on the heat-treatment-furnace strip chart recorder

(strip chart recorder) indicated that they were being calibrated annually, instead of quarterly. 

The SFIPD QAM was revised to require the calibration of the strip chart recorder annually. 

SFIPD had revised the ìM&TE Equipment Assigned Frequencies Listî earlier, requiring the strip

chart recorders to be calibrated annually. During this inspection, the auditors verified the

validity of calibration stickers on several SFIPD measuring items used for products supplied to

BSC. During this activity, the auditors observed that there was no valid calibration sticker on

the strip chart recorders, but instead a maintenance sticker from an Energy Services Group,

Incorporated (ESG). Honeywell, Incorporated (Honeywell) performs the calibration on the strip

chart recorders. After reviewing the maintenance records performed on the recorder, SFIPD

personnel were able to prove that ESG pasted its maintenance sticker over Honeywellís sticker,

and obscured it. The auditors were satisfied and identified no adverse findings in this area. 

The observers agreed with the audit team findings in this area.

4.5.4 Nonconformance Control

The audit team reviewed selective nonconformance reports (NCRs) to determine if they were

closed in accordance with Section 8 of the SFIPD. During the conduct of a Supplier Survey, the

results of which are documented in the Supplier Survey Report BSC-01-008, BSC had an

adverse observation. However, because BSC made the observation during a Supplier Survey,

BSC identified the observation as a recommendation instead of a deficiency. BSC observed

that the disposition in NCR N-01-012 was for the nonconforming material to be used ìuse-asis.î Section 8 of the SFIPD QAM requires that whenever nonconforming material is to be used

ìuse-as-is,î an MRB has to be convened to review and concur with the disposition. Contrary to

this requirement, NCR N-01-012 was closed without convening an MRB. SFIPD implemented

BSCís recommendation by evaluating all the previous NCRs that required MRB review and

closed the action on the adverse finding. During the current audit, BSC observed that in NCR

N-01-023, even though the rejected material was recommended to be used ìuse-as-is,î SFIPD

closed the NCR without technical justification and without convening an MRB. BSC also

identified that in NCR N-01-028, even though the disposition was to repair the rejected material,

SFIPD closed it without convening an MRB. BSC identified that the closure of the two NCRs

was a deficiency, and contrary to Section 8 of the SFIPD QAM. BSC combined the improper

closure of two NCRs and identified it as one deficiency. 

The observers agreed with the audit team findings in this area.
-7-

4.5.5 Supplier Deviation Disposition Requests

BSC, in Section XV, ìAcceptance Method,î of its ìTechnical Services Statement of Work for

Waste Package Weld Flaw Analysisî states, the supplier shall notify the purchaser (BSC) when

the supplier identifies any nonconformances (deviation) from the procurement document. This

notification shall be performed using Appendix 4, ìBSC Supplier Deviation Disposition Requestî

(SDDR). NCRs where the proposed disposition is repair, or use-as-is, are required to be

submitted to the purchaser for review and concurrence.î NCR N-02-008, dated January 29,

2002, pertained to the fabrication of welded rings, and indicates that SFIPD did not heat-treat

test-specimen welded cylinders in compliance with ìHeat Treatment Instruction Sheet,î

Procedure H87130N390HT2, Revision 2. Specifically, the procedure required a minimum of

three Thermocouples (TCs) to be attached to the cylinder in pairs; each pair was to be placed

no closer than 6-inches (in.) and no farther than 12-in. apart, with each pair located at the

center of the cylinder 180 degrees apart in rotation from the other. During the heat-treatmentfurnace run, two TCs remained intact and the other two slipped away. This resulted in two TCs

measuring the actual material temperature that is reflected in the chart. The cause for the TCs

slipping away was identified to be insufficient backup restraining devices to keep the TCs in

place. Corrective action recommended to preclude repetition was to install necessary

restraining devices to obtain continuous temperature reading. The disposition of the NCR was

ìuse-as-is.î SFIPD initiated an SDDR and sent it to BSC for review and approval. The audit

team had no adverse findings in this area.

The observers agreed with the audit team findings in this area.

4.5.6 Personnel Training Records

SFIPD gives training to its employees, and documents such activity in Personnel Training

Records (PTRs). A PTR dated January 11, 2002, pertained to the Yucca Mountain Project job

Procedure H87130-WFR-1, Revision 0, dated January 9, 2002, and contained the signatures of

the participants, outlined the topics discussed during the training, and identified the numerous

SFIPD documents pertaining to the subject. A PTR dated January 24, 2002, indicated that

SFIPD personnel were trained in the revision to Procedure H87130-WFR-1, Revision 1, dated

January 24, 2002, ìProcedure for Documenting the Location and Orientation of Flaws.î This

procedure establishes the method of recording the location and orientation of flaws identified by

radiographic, liquid penetrant , ultrasonic, or eddy-current NDE for the waste package weld-flaw

analysis project. SFIPD had revised Procedure H87130-WFR-1, Revision 0, dated January 9,

2002, incorporating the comments received from BSC. All participants signed the PTR. The

audit team had no adverse findings in this area.

The observers agreed with the audit team findings in this area.

5.0 NRC STAFF FINDINGS

The observers determined that Audit No. BSC-SA-02-009 was effective in determining the level

of compliance of SFIPD activities associated with sample fabrication. The observers agreed

with the audit teamís conclusion that the purchase orders, QARD, and SFIPD QAP had been

satisfactorily implemented, except for the identified potential deficiency.
-8-

5.1 NRC Audit Exit Summary

The audit team discussed the inspection elements reviewed during the audit exit meeting. Of

particular interest was the fact that there was only one deficiency identified with the controls

established for the disposition of nonconformances. The observers expressed appreciation for

the excellent cooperation and responsiveness provided to them during their observation

activities. In addition, the observers stated that they agreed with the audit teamís findings and

recommendations, as presented at the audit exit. The observers also stated that they will

continue to interface with DOE and BSC and follow the progress that SFIPD is making to

correct the deficiency identified during this audit.

5.2 NRC Audit Observer Inquiries

There were no Audit Observer Inquiries written during this audit.