AUDIT REPORT

Audit of NRC’s Use of Confirmatory Action Letters

OIG-12-A-09 February 10, 2012

All publicly available OIG reports (including this report) are accessible through

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

OFFICE OF THE

INSPECTOR GENERAL

February 10, 2012

MEMORANDUM TO: R. William Borchardt

Executive Director for Operations

FROM: Stephen D. Dingbaum /RA/

Assistant Inspector General for Audits

SUBJECT: AUDIT OF NRC’S USE OF CONFIRMATORY ACTION 

LETTERS (OIG-12-A-09)

Attached is the Office of the Inspector General’s (OIG) audit report titled, Audit of NRC’s

Use of Confirmatory Action Letters.

The report presents the results of the subject audit. Agency comments provided at the 

January 20, 2012, exit conference have been incorporated, as appropriate, into this 

report.

Please provide information on actions taken or planned on each of the 

recommendations within 30 days of the date of this memorandum. Actions taken or 

planned are subject to OIG followup as stated in Management Directive 6.1.

We appreciate the cooperation extended to us by members of your staff during the 

audit. If you have any questions or comments about our report, please contact me at 

415-5915 or RK Wild, Team Leader, Nuclear Reactor Safety Audits Team, at 415-5948.

Attachment: As stated 
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BACKGROUND

The Nuclear Regulatory Commission (NRC) regulates commercial nuclear 

power plants and other civilian uses of nuclear materials, such as in 

nuclear medicine, through licensing, inspection, and enforcement of its 

requirements. In exercise of its regulatory responsibilities, NRC uses 

administrative actions, such as Confirmatory Action Letters (CALs) to 

supplement the agency’s enforcement program. CALs are “letters 

confirming a licensee's agreement to take certain actions to remove 

significant concerns about health and safety, safeguards, or the 

environment.” 

Administration of Confirmatory Action Letters

The NRC Office of Enforcement is responsible for the development and 

implementation of the NRC Enforcement Policy (Policy) and the NRC 

Enforcement Manual (Manual). The Policy sets forth the general 

principles governing NRC’s enforcement program. The Manual contains 

guidance on preparation, issuance, coordination, tracking, and closure of 

CALs and delegates authority for issuing CALs to the NRC regional 

administrators and some program office directors. 

OBJECTIVE

The audit objective was to determine the effectiveness of NRC’s utilization 

of CALs as a regulatory tool. To meet this objective, Office of the 

Inspector General (OIG) auditors focused on the agency’s administration 

of the CAL process. 

RESULTS IN BRIEF

NRC’s administration of the CAL process is not as effective as it could be.

Specifically, CAL guidance is inconsistent because the CAL guidance 

does not include some offices’ roles or clearly identify all CAL recipients. 
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Further, NRC program and regional offices do not fully comply with CAL 

guidance. Despite requirements contained in the Manual for the 

concurrence, tracking, and numbering of CALs, 

Some required office concurrences on CALs are missing.

CAL tracking practices vary among offices. 

CAL numbering conventions vary among offices.

Weaknesses in NRC’s CAL guidance and compliance with the guidance 

exists because the agency does not have a centralized control point for 

agencywide oversight and implementation of a fully effective CAL process, 

including consistent CAL guidance, compliance with the guidance, and the 

tracking of CALs.

Consequently, NRC may be missing opportunities to effectively use CALs

for potential CAL recipients not identified in current guidance and to 

efficiently track and trend CALs. 

RECOMMENDATIONS 

This report makes four recommendations to improve the agency’s process 

for administering CALs. A list of these recommendations appears on page

11 of this report.

AGENCY COMMENTS 

On January 10, 2012, OIG issued the discussion draft of this report to the 

Executive Director for Operations. OIG met with NRC management 

officials and staff on January 20, 2012, at an exit conference to discuss 

the draft report. At this meeting, agency management stated its 

agreement with the report recommendations and provided informal 

comments for OIG to consider for incorporation into the report. OIG 

incorporated the agency comments into the report as appropriate. NRC 

management and staff reviewed and agreed with the revisions and opted 

not to provide formal comments for inclusion in this report.
iii

ADAMS Agencywide Documents Access and Management System

Appendix B 10 CFR Part 50, Appendix B

CAL Confirmatory Action Letter

CFR Code of Federal Regulations

FSME Office of Federal and State Materials and Environmental 

Management Programs

Manual NRC Enforcement Manual 

NMSS Office of Nuclear Material Safety and Safeguards

NRC Nuclear Regulatory Commission 

NRO Office of New Reactors

NRR Office of Nuclear Reactor Regulation

NSIR Office of Nuclear Security and Incident Response

OE Office of Enforcement

OIG Office of the Inspector General 

Policy NRC Enforcement Policy 
iv

TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................. i

ABBREVIATIONS AND ACRONYMS.........................................iii

I. BACKGROUND.................................................................. 1

II. OBJECTIVE ....................................................................... 3

III. FINDING............................................................................. 3

NRC’s Approach to CAL Administration Is Not as 

Effective as it Could Be ................................................. 4

Recommendations ..................................................... 11

IV. AGENCY COMMENTS..................................................... 11

APPENDICES

A. EXAMPLE OF A RECENTLY ISSUED

CONFIRMATORY ACTION LETTER......................... 12

B. OBJECTIVE, SCOPE, AND METHODOLOGY.......... 16
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I. BACKGROUND

The Nuclear Regulatory Commission (NRC) regulates commercial nuclear 

power plants and other civilian uses of nuclear materials, such as in 

nuclear medicine, through licensing, inspection, and enforcement of its 

requirements. In exercise of its regulatory responsibilities, NRC uses 

administrative actions, such as Confirmatory Action Letters (CALs), to 

supplement the agency’s enforcement program. CALs are “letters 

confirming a licensee's agreement to take certain actions to remove 

significant concerns about health and safety, safeguards, or the 

environment.” Appendix A of this report contains an example of a CAL 

that NRC recently issued.

The origins of CALs can be traced to 1974. At that time, NRC created 

Immediate Action Letters that the agency would use to confirm a 

recipient’s commitment to certain actions. NRC also used the letters to 

document cases where the recipient voluntarily agreed to cease 

operations until the recipient properly evaluated and corrected the 

situation. In 1982, the agency changed the name from Immediate Action 

Letters to Confirmatory Action Letters. 

NRC expects the recipient of a CAL to adhere to any obligations and 

commitments addressed in the letter. CALs do not establish legally 

binding commitments with the exception of a provision to report 

information to NRC. If a recipient failed to meet a commitment in a CAL, 

according to agency guidance, NRC would likely proceed with stringent

enforcement sanctions such as an order. An order is an enforcement 

sanction that NRC issues to modify, suspend, or revoke licenses or to 

impose civil penalties. 

Administration of Confirmatory Action Letters

The NRC Office of Enforcement (OE) is responsible for the development 

and implementation of the NRC Enforcement Policy (Policy) and the NRC 

Enforcement Manual (Manual). The Policy sets forth the general 

principles governing NRC’s enforcement program. The Manual contains 

guidance on preparation, issuance, coordination, tracking, and closure of 

CALs. 
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The Manual delegates authority for issuing CALs to the NRC regional 

administrators and the directors of the Office of Nuclear Reactor 

Regulation (NRR), the Office of Nuclear Material Safety and Safeguards

(NMSS), the Office of Federal and State Materials and Environmental 

Management Programs (FSME), and the Office of New Reactors (NRO).

The Manual also states that offices with the potential for issuing CALs 

have the responsibility for preparing, issuing, coordinating as required, 

tracking the status, and appropriately closing out CALs. 

When asked about CAL guidance that program and regional offices use, 

some program offices and regions identified office instructions and 

inspection guidance, in addition to the Policy and Manual, as a source of 

guidance, as shown in Table 1.

Table 1: Additional CAL Guidance Provided by NRC Offices and Regions

Guidance Offices

NRR NMSS FSME NRO NSIR RI RII RIII RIV

Office 

Instructions

X X X X X

Inspection 

Guidance

X X X

Note: NSIR is the Office of Nuclear Security and Incident Response. The four NRC regions are indicated as 

RI, RII, RIII, and RIV. 

Source: OIG analysis of CAL guidance provided by NRC offices and regions

From January 1, 2000, to April 30, 2011, NRC issued approximately 195

CALs to different entities, including nuclear power plants, decommissioned 

reactors, research and test reactors, materials licensees, certificate of 

compliance holders,

1

and non-licensees. During this approximate 11-year 

period, the agency has issued on average 17 CALs each year, with NRR 

issuing the most and Region I issuing the second largest number of CALs. 

 

1

A certificate of compliance holder is an entity that has a certificate issued by the Commission approving 

the design of a spent fuel storage cask in accordance with Title 10 Code of Federal Regulations (10 CFR) 

Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level 

Radioactive Waste and Reactor-Related Greater than Class C Waste.
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II. OBJECTIVE

The audit objective was to determine the effectiveness of NRC’s utilization 

of CALs as a regulatory tool. To meet this objective, Office of the 

Inspector General (OIG) auditors focused on the agency’s administration 

of the CAL process. Appendix B contains information on the audit scope 

and methodology.

III. FINDING

NRC’s administration of the CAL process is not as effective as it could be. 

The agency position is that CALs are a valuable enforcement tool for 

obtaining timely confirmation that the recipient has agreed to take action 

that will remove significant concerns regarding health and safety, the 

environment, safeguards, or security. As such, maintaining a viable and 

consistent CAL program is of utmost importance to the agency. 

NRC’s CAL guidance lacks consistency and the agency does not fully 

comply with its guidance. This is because NRC does not have a 

centralized control point for agencywide oversight and implementation of a 

fully effective CAL process, including consistent CAL guidance, 

compliance with the guidance, and the tracking of CALs. Consequently, 

NRC may be missing opportunities to effectively and efficiently administer 

the use of CALs.

Requirements for Effective Programs

Federal internal control standards provide for continuous program 

assessment and evaluation to assure program effectiveness. Standards

for Internal Control in the Federal Government state that Federal program 

managers must provide continuous mission and program internal control 

assessment and evaluation. 

In implementing these standards, management is responsible for 

developing internal controls—such as detailed policies, procedures, 

guidance, and practices—to fit their agency’s operations and be an 

integral part of daily operations. Specifically, achieving effective 

administration of the CAL process requires consistent guidance and

compliance with the established guidance.
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NRC’s Approach to CAL Administration Is Not as Effective as It 

Could Be 

NRC’s administration of the CAL process is not as effective as it could be. 

There is a lack of consistency in the agency’s CAL guidance. Moreover, 

program and regional offices do not fully comply with CAL guidance.

CAL Guidance Is Inconsistent

Agency guidance for CAL implementation has inconsistencies. For 

example, CAL guidance does not include some offices’ roles or clearly 

identify all CAL recipients.

The Manual does not consistently identify some offices’ roles pertaining to 

CAL administration. Two offices that the Manual does not acknowledge 

consistently are FSME and NRO. In its “Responsibilities and Authorities” 

section, the Manual authorizes the Directors of FSME and NRO to sign 

and issue CALs. However, the Manual is silent on FSME’s and NRO’s 

role in virtually all remaining sections, even though those sections mention 

other agency offices by name. These sections include:

CAL Coordination and Review.

CAL Signature Authority.

Licensee Notification, Mailing and Distribution for CALs.

CAL Tracking Responsibilities.

Closing Out CALs.

Moreover, CAL guidance does not clearly identify all CAL recipients. The 

entities that the Policy identifies as CAL recipients are licensees or 

contractors, whereas the Manual states CAL recipients are licensees or 

vendors. In addition, Inspection Procedure 92703, Followup of 

Confirmatory Action Letters or Orders, states CAL recipients are licensees

or individuals. As illustrated in Table 2, it is unclear who the intended CAL 

recipients are. 
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Table 2: Recipients Identified in CAL Guidance

Source: OIG analysis of CAL guidance provided by NRC offices and regions

Furthermore, the Manual clearly states that CALs should not be used to 

remove an individual from, or restrict his or her ability to perform, licensed 

activities. The Manual further cautions against the use of CALs for 

individuals because, in such instances, individual rights are affected and 

the opportunity for a hearing must be given both to the licensee and to the

affected individual. 

The variety of CAL recipients and the types of concerns addressed in 

CALs that NRC issued are illustrated in Table 3.

Table 3: Various Recipients and Concerns Addressed in CALs

Recipient Type Concern Issuing Office

Commercial Power 

Reactor Licensee

Inattentive security guards Region I

Research and Test 

Reactor Licensee

Unexpectedly high dose rates NRR

Medical Use Licensee No radiation safety officer and 

broken lock

Region I

Fuel Cycle Facility

Licensee

Unacceptable enriched uranium 

configuration

Region II

Certificate of Compliance 

Holder

Waste transportation drum

performance

NMSS

Real Estate Company 

Non-Licensee in 

Possession of Materials

Unlicensed tritium found in 

building 

Region II

Source: OIG analysis of agency-provided documentation 

Licensees Contractors Vendors Individuals

Policy X X

Manual X X

Inspection 

Procedure 92703

X X
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Agency Offices Do Not Fully Comply With CAL Guidance

NRC program and regional offices do not fully comply with CAL guidance.

Despite requirements contained in the Manual for the concurrence, 

tracking, and numbering of CALs, 

Some required office concurrences on CALs are missing.

CAL tracking practices vary among offices.

CAL numbering conventions vary among offices.

Concurrences on CALs Are Missing

Some required office concurrences on CALs are missing. The Manual

requires the Director, NRR, to concur on CALs issued to reactor licensees

and the Director, Office of Nuclear Security and Incident Response

(NSIR), to concur on security-related CALs. However, OIG identified 

several CALs issued to reactor licensees that did not have NRR 

concurrence, as well as several security-related CALs that did not have 

NSIR concurrence. 

CAL Tracking Practices Vary

Tracking practices vary among the agency’s program and regional offices 

despite agency guidance that requires accounting of specific information. 

The Manual stipulates that offices and regions should maintain a list 

summarizing the following information that would be suitable for auditing 

purposes:

How many CALs have been issued. 

To whom the CAL has been issued. 

Why the CAL was issued, i.e., a brief description of the issues. 

When all corrective actions were or will be completed. 

None of the program and regional offices maintain tracking lists that 

adequately provide all the information as required by the Manual. The 

methods offices and regions use for tracking the CALs issued vary from 

no tracking to some method of tracking, but without the information 

needed for auditing purposes. 
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Agency officials provided various explanations for why they do not track 

CALs. Reasons included issuing too few CALs to justify a tracking system

and relying on other offices to track CALs.

Some offices also indicated that they rely on the Agencywide Documents 

Access and Management System (ADAMS)2for locating and knowing the 

status of their CALs. However, ADAMS is a document repository, not a 

tool to track the information to the degree of specificity that the Manual 

requires. Further, ADAMS is vulnerable to user-introduced inaccuracies.

For example, CALs in ADAMS do not have consistent profile descriptions,3

which made it difficult for agency and OIG staff to search for and locate 

documents in ADAMS. In some cases, offices inconsistently profiled or 

described CALs as “letter,” “inspection report,” and/ or “CAL.” When 

asked for a list of CALs, at least one office that issues CALs and relies 

solely on ADAMS for tracking, overlooked a number of CALs because the 

CALs were profiled inconsistently.

Numbering Conventions Vary

Some offices used numbering conventions that vary from the required 

numbering format. The Manual states that the issuing program or regional

office assigns the CAL a tracking number based on the office acronym, 

the year of issuance, and the sequential CAL number for that year (e.g., 

XXXX-06-008). However, in some instances, offices used variations of 

this format, including CAL numbers with no clear indication of the program 

or regional office acronym, the year issued, and/or the sequential CAL 

number for that year. One office was not internally consistent with its own 

numbering scheme, using variations of CAL numbering conventions 

including 02-8-00 and XXXX-2010-001. Use of numbering conventions 

that varied from the required numbering format has likely led to the use of 

duplicate CAL numbers identified during this audit. 

 

2

ADAMS is NRC’s official recordkeeping system that contains vast libraries or collections of documents 

related to the agency’s regulatory activities.

3

Every document in ADAMS has a document profile that stores information about the document, such as 

author, title, docket number, public availability, etc. The document profile provides consistent fields of 

information needed to identify, locate, list, and manage documents. For example, the document profile 

has properties that describe the Document Date, Document Sensitivity, Author Name, etc.
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NRC Would Benefit From a Centralized Control Point To Oversee the 

CAL Process Agencywide 

NRC currently does not have a centralized control point for oversight and 

implementation of an effective agencywide CAL process to include holding 

program and regional offices accountable for following CAL guidance. If 

the agency had a centralized control point, it would be able to, among 

other things:

Assess and update the Policy, the Manual, and other associated 

guidance to ensure that NRC’s approach for utilizing CALs is 

consistent, effective, and efficient. With authority over guidance, a 

centralized control point would be uniquely positioned to serve as a 

resource for program and regional offices issuing CALs. Even 

though no such control point currently exists at NRC, some 

program and regional office points-of-contact were under the 

impression that OE was already fulfilling this role to offer 

clarification of guidance and track their CALs. 

Conduct periodic CAL audits that verify compliance with CAL 

policies and procedures. In fact, in 2004, OE conducted an audit of 

agencywide CALs and found some tracking and numbering issues 

similar to those described in this OIG report. Yet, without being 

designated as a clear agencywide control point for CALs, the office 

lacked leverage to encourage the changes and lost institutional 

memory that it had conducted the audit.

Implement a comprehensive, agencywide CAL tracking system.

Doing so would eliminate the confusion over numbering schemes 

and sequences, and help to ensure agency staff and management 

awareness of the status of open CALs.

NRC Offices May Be Missing Opportunities To Effectively and 

Efficiently Administer the Use of CALs

Without a centralized control point for oversight of the CAL process, NRC 

may be missing opportunities to administer the use of CALs more 

effectively and implement the CAL program more efficiently. Among other 

things, this makes it challenging for the agency to ensure that all items 

committed to by CAL recipients have been met.
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Opportunities To Use CALs More Effectively 

NRC may be missing opportunities to use CALs more effectively. 

Additionally, NRC may have been out of compliance with current guidance 

on who can receive a CAL. NRC has issued CALs to recipients not clearly 

identified in the Policy or Manual. For example, in one case, the CAL 

recipient — although not a licensee, vendor, or contractor — was able to 

take action expeditiously to address significant concerns about health,

safety, and the environment. The flexibility to issue a CAL to a nonlicensee who was in possession of nuclear materials may be a very 

effective use of a CAL. However, because the Policy and Manual do not 

identify non-licensees as potential CAL recipients, other NRC staff would 

not necessarily know that CALs could be effectively used in this manner. 

NRC may also be missing the opportunity to issue CALs to vendors.

According to NRC staff, the agency has not issued CALs to the vendors

that NRC inspects in accordance with 10 CFR Part 50, Appendix B

(Appendix B).

4 An NRC staff member stated that during a vendor 

inspection, if the Appendix B vendor’s quality assurance program is 

inadequate, it is conceivable that issuing a CAL would be useful. 

However, NRC’s Vendor Inspection Program staff have not pursued the 

use of CALs as a possible tool for vendors.

Program Implementation Efficiencies Are Impacted

NRC may also be missing opportunities to implement the CAL program

more efficiently, primarily with regard to the agency’s CAL tracking efforts. 

Currently, the agency supports multiple CAL tracking systems that have 

varying degrees of effectiveness for identifying the universe of both open 

and closed CALs, and determining the status of open CALs. In requesting 

CALs from each of the program and regional offices, OIG found more 

CALs than offices reported. Further, OIG and NRC staff found it difficult to 

locate CAL closure letters, thus demonstrating that staff do not have CAL 

status information readily available. Without readily available CAL status 

information, the agency cannot determine in a timely fashion whether a 

CAL recipient has met all of the commitments described in the CAL.

 

4

10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants, requires that a quality assurance program be applied to all activities affecting 

structures, systems, and components of reactors that prevent or mitigate the consequences of postulated 

accidents that could cause undue risk to the health and safety of the public. The appendix establishes 

quality assurance requirements for the design, manufacture, construction, and operation of those 

structures, systems, and components.
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Further, NRC may be missing trending opportunities by having several 

dispersed CAL tracking systems. Trending CAL data provides an ongoing 

record of system performance. Specifically, having the capability to trend 

all of NRC’s CALs enables NRC to have a running record of CALs to 

perform baseline comparisons, identify repeating issues, and monitor the 

agency’s CAL activities. 

Conclusion

The agency views the CAL as an effective and efficient means for 

obtaining timely confirmation of actions a recipient has agreed to take in 

order to remove significant concerns about public health, safety, 

safeguards, security, or the environment. As such, CALs support NRC’s 

overall safety mission. However, program implementation weaknesses,

such as inconsistent CAL guidance, prevent staff from using CALs to their 

full potential and degrade NRC’s overall CAL program accountability. 

Sustained non-compliance with established guidance may indicate weak 

organizational accountability.

Strengthening organizational management with a centralized control point 

for CALs would improve the agency’s oversight of and accountability for

CAL program requirements. Implementing such oversight would result in 

improvements to NRC’s overall approach for using the CAL process. 

More importantly, it would further support the agency’s responsibility for 

overseeing the Nation’s safe operation of commercial nuclear power 

plants and other uses of nuclear materials to ensure that the public and 

environment are adequately protected. 
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Recommendations

OIG recommends that the Executive Director for Operations:

1. Designate a centralized control point to oversee and implement an 

effective agencywide CAL process.

2. Assess and update the NRC Enforcement Policy, the NRC

Enforcement Manual, and other associated guidance to ensure that 

NRC’s approach for utilizing CALs is consistent, effective, and 

efficient.

3. Conduct periodic CAL audits that verify compliance with CAL policies 

and procedures.

4. Implement a comprehensive, agencywide CAL tracking system.

IV. AGENCY COMMENTS

On January 10, 2012, OIG issued the discussion draft of this report to the 

Executive Director for Operations. OIG met with NRC management 

officials and staff on January 20, 2012, at an exit conference to discuss 

the draft report. At this meeting, agency management stated its 

agreement with the report recommendations and provided informal 

comments for OIG to consider for incorporation into the report. OIG 

incorporated the agency comments into the report as appropriate. NRC 

management and staff reviewed and agreed with the revisions and opted 

not to provide formal comments for inclusion in this report.
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Appendix A

Example of a Recently Issued Confirmatory Action Letter 
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Appendix B

OBJECTIVE, SCOPE, AND METHODOLOGY

OBJECTIVE

The audit objective was to determine the effectiveness of NRC’s utilization 

of Confirmatory Action Letters as a regulatory tool. 

The audit focused on reviewing the agency’s administration of the CAL

process by examining relevant documents and conducting interviews with 

agency staff. While the audit primarily reviewed current agency guidance 

and practices with regard to CALs, auditors also reviewed CALs issued 

since January 1, 2000. We conducted this performance audit at NRC 

headquarters (Rockville, MD) from May 2011 through November 2011. 

Internal controls related to the audit objective were reviewed and 

analyzed. Throughout the audit, auditors were aware of the possibility or 

existence of fraud, waste, or misuse in the program.

OIG reviewed agency regulations regarding NRC’s use of CALs, including

the NRC Enforcement Policy and the NRC Enforcement Manual. OIG 

also reviewed office-specific guidance on CALs, including LIC-100, 

Control of Licensing Bases for Operating Reactors; and Regional Office 

Instruction No. 0904, Confirmatory Action Letters. Furthermore, OIG 

reviewed NRC inspection manual chapters, inspection procedures, and 

CALs issued between January 1, 2000, and April 30, 2011, which totaled 

195 CALs.

OIG interviewed NRC staff who are involved in CAL-related activities. 

These interviews included a deputy executive director, office directors, 

deputy directors, project managers, and enforcement specialists. Overall, 

OIG conducted interviews with all program and regional office points-ofcontact identified by the agency to obtain staff insights into the agency’s 

use of CALs. 
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We conducted this performance audit in accordance with generally 

accepted Government auditing standards. Those standards require that 

we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

audit objective. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit 

objective. 

The audit work was conducted by Sherri Miotla, Team Leader; R.K. Wild, 

Team Leader; Kevin Nietmann, Senior Technical Advisor; Vicki Foster, 

Audit Manager; and Andrea Ferkile, Senior Management Analyst. 

Additional support was provided by Jacki Storch, Audit Manager; Robert 

Woodward, Audit Manager; and Maxinne Lorette, Senior Auditor.