Attachment B - EIC-DET-SOW-026 Statement of Work for the Forward Hadronic Calorimeter Absorber Structure.docx

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Forward Hadronic Calorimeter Absorber Structures
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This Statement of Work (SOW) details the procurement of Forward Hadronic Calorimeter Absorber Structures for the Electron-Ion Collider (EIC) detector at Brookhaven National Laboratory. The initial contract scope includes manufacturing and testing five pre-production 8M steel absorber modules, with a potential follow-on production of 645 8M modules and additional optional modules (416 8M and 72 4M). The modules are critical components of the detector's forward hadronic calorimeter, designed as an Iron-Scintillator sampling sandwich calorimeter with 60 layers, each module serving as part of the detector's solenoid magnetic flux return.

The contract requires detailed manufacturing, inspection, and testing processes, with key milestones including delivery of pre-production units within 10 calendar weeks after contract award, BSA evaluation of pre-production units by week 16, and potential subsequent module deliveries in batches through week 130. The contractor must maintain ISO-9001 compliant quality assurance, provide comprehensive documentation, and undergo testing at Oak Ridge National Laboratory (ORNL). The project is managed by Brookhaven Science Associates (BSA) under the Department of Energy (DOE) Office of Science, with the ultimate goal of completing calorimeter module assembly and installation in the EIC detector's Experimental Hall by 2029.

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STATEMENT OF WORK

for the Forward Hadronic Calorimeter Absorber Structure Quality Classification: A-3

Prepared By:

______________________________________ Date: __________________ Oleg Eyser, Senior Physicist

Reviewed By:

______________________________________ Date: __________________ Maggie Haviland, EIC Procurement Liaison Engineer

______________________________________ Date: __________________ Dan Cacace, Mechanical Engineer

______________________________________ Date: __________________ Joseph Zipper, EIC Quality Representative

______________________________________ Date: __________________ Chuck Schaefer, EIC ESH Manager

Approved By:

______________________________________ Date: __________________ Elke Aschenauer, Level 2 Manager – EIC Detector Systems

Electron-Ion Collider, Brookhaven National Laboratory

Doc No. EIC-DET-SOW-026
Author: Oleg Eyser
Effective Date:
Review Frequency: N/A
SOW: Forward Hadronic Calorimeter Absorber Structure
Revision: 05

2 National Synchrotron Light Source II

Version n 10 of 8 nnMon2009 Brookhaven National Laboratory

This page intentionally left blank, to accommodate back-to-back printing.

Electron-Ion Collider, Brookhaven National Laboratory

Doc No. EIC-DET-SOW-026
Author: Oleg Eyser
Effective Date:
Review Frequency: N/A
SOW: Forward Hadronic Calorimeter Absorber Structure
Revision: 05

REVISION HISTORY

Revision #
Effective Date
Summary of Change
00
12/5/2024
Initial Release
01
1/15/2025
Revised Section 6 Schedule
02
4/7/2025
Included production units as options contingent on BSA-approval of five (5) pre-production units
03
6/3/2025
Revised Section 3.2.2 to indicate testing of first articles will occur at ORNL, removed approval by BSA Technical Representative from Section 3.3.5 and Section 3.4.2, revised Section 4.6.3 to include written approval by the BSA Technical Representative and BSA Contract Specialist, revised Section 5 Deliverables
04
7/15/2025
Section 6 Schedule updated to indicate production units as an option, removed third party testing from Section 4.6.2

Revised to include initial 645 8M module production units as part of the base contract, BNL-QA-101 Clause 4.24 added to Section 4.1, noted that records will be maintained by the Contractor in Section 4.2

Table of Contents

LIST OF ACRONYMS6
1SCOPE7
1.1 Background7
2APPLICABLE DOCUMENTS8
3REQUIREMENTS8
3.1 Contractor Responsibilities8
3.1.1Technical Performance8
3.1.2Tooling/Fixtures/Test Equipment9
3.1.3Materials9
3.2 Manufacturing Requirements9
3.2.1Detailed Analysis Requirements9
3.2.2Approval to Proceed9
3.2.3Manufacturing, Inspection and Test Requirements9
3.2.4Acceptance Test Procedures (ATP)9
3.3 Management10
3.3.1Program Plan10
3.3.2Progress Communications10
3.3.3Manufacturing/Inspection/Test Plan10
3.3.4Performance Reporting10
3.3.5“Witness” Points10
3.4 Documentation and Data Management11
3.4.1Report/Documentation Format11
3.4.2End Item Documentation Package11
3.4.3Records12
3.5 Marking and Serialization12
4QUALITY ASSURANCE12
4.1 Quality System and Facility Access12
4.2 Configuration Management13
4.3 Responsibility for Subcontractor13
4.4 Responsibility for Conformance13
4.5 Measuring and Test Equipment (M&TE) Calibration13
4.6 Inspections and Test Requirements14
4.6.1Acceptance Testing14
4.6.2Pre-Production Unit Acceptance14
4.6.3Approval for Production14
4.7 Repairs14
4.8 Failure Reporting, Analysis and Corrective Action15
5DELIVERABLES16
6SCHEDULE16
7VALUE ENGINEERING17

10 National Synchrotron Light Source II

Electron-Ion Collider, Brookhaven National Laboratory

Doc No. EIC-DET-SOW-026
Author: Oleg Eyser
Effective Date:
Review Frequency: N/A
SOW: Forward Hadronic Calorimeter Absorber Structure
Revision: 05

LIST OF ACRONYMS

ATP
Acceptance Test Procedure
BNL
Brookhaven National Laboratory
BSA
Brookhaven Science Associates
DOE
Department of Energy
EIC
Electron-Ion Collider
Fe/Sc
Iron-Scintillator
IP-6
Experimental Hall of the EIC Detector
ISO
International Organization for Standardization
LFHCal
Longitudinally segmented Forward Hadronic Calorimeter
MRP
Material Requirements Planning
M&TE
Measuring and Test Equipment
NIST
National Institute of Standards and Technology
ORNL
Oak Ridge National Laboratory
PO
Purchase Order
QA
Quality Assurance
SOW
Statement of Work

Statement of Work for the Forward Hadronic Calorimeter Absorber Structure

1. SCOPE

This Statement of Work (SOW) will be the basis for the procurement of the Absorber Structure for the Longitudinally segmented Forward Hadronic Calorimeter (LFHCal) of the Electron-Ion Collider (EIC) General Purpose detector to be built in the EIC interaction region IP-6 (Experimental Hall of the EIC Detector) at Brookhaven National Laboratory (BNL) managed by Brookhaven Science Associates (BSA). This document outlines the Contractor’s responsibilities and obligations necessary for completing the requirements as set forth herein.

0. Background The EIC Project will design, build, and install the accelerator hardware for a new electron storage ring, an electron injector, and modifications to the hadron ring required to produce an electron-ion collider and its infrastructure. It will include one interaction region, with an allowance for a second, and one detector. The facility is designed to meet requirements to ensure high reliability and availability for the user program.

The detector in IP-6 will provide an almost 4 coverage in tracking, particle identification, electromagnetic and hadronic calorimetry. The hadronic calorimeter in the forward (hadron-going) endcap is of a particular importance, to measure highly energetic particle jets with a sufficient energy resolution, isolate the jet neutral components (neutrons and KL particles), complement tracking and electromagnetic calorimetry in particle flow algorithms, and be an integral part of the detector solenoid magnetic field flux return.

The LFHCal is an Iron-Scintillator (Fe/Sc) sampling sandwich calorimeter, where 16 mm thick steel plates are alternated with 4 mm thick scintillator plates (for a total of 60 layers each) with a depth of around 1.32 meters. All absorber layers will be made of a magnetic carbon steel because they are part of the EIC detector solenoid magnetic flux return. The full LFHCal is comprised of 1138 modules; 1066 are of the 8M layout and 72 are of the 4M layout. The 8M modules have a transverse size of about 200 mm (width) by 100 mm (height) and the 4M modules are one half of an 8M module in transverse size (100 mm x 100 mm). In addition, there are two insert modules (insert left and insert right) which have a combined transverse size of 600 mm x 600 mm with a conical opening to allow for the beampipe to pass through. The steel pieces are electron-beam welded to one module and the full weldment is nickel-plated to prevent corrosion. The total scope of this Statement of Work is for an initial five (5) pre-production steel absorber modules of type 8M, with follow-on production of 645 8M modules (subject to acceptance of the 5 pre-production units) and additional option(s) for 416 8M modules and 72 4M modules.

Early start of procurement of these Absorber Steel Structures is of a paramount importance for EIC, since it allows one to start the calorimeter module assembly shortly after the Department of Energy (DOE) CD-3 approval, and therefore finish the assembly and installation in IP-6 in 2029, on time for the solenoid acceptance tests.

1 APPLICABLE DOCUMENTS

In the event of a conflict between the Technical Documentation and this SOW, the Contractor shall immediately notify the BSA Contractual Representative who will in each instance determine which document takes precedence and advise the Contractor accordingly. Failure to notify BSA of a document conflict shall not relieve the Contractor’s responsibility to ensure full compliance to all requirements.

The following documents are an integral part of the SOW; the applicable revision level will be the latest that is in effect at the time of award:

Document Number
Document Title
EIC-DET-SPC-021
Technical Specification for the Forward Hadronic Calorimeter Absorber Structure
BNL-QA-101
Brookhaven National Laboratory Supplier Quality Assurance Requirements
EPC-FWD-HCL-DET-ASM-100
A full set of engineering drawings for 8M modules
EPC-FWD-HCL-DET-ASM-200
A full set of engineering drawings for 4M modules

REQUIREMENTS

In accordance with the applicable specifications, referenced documents, and instructions as defined in this Statement of Work, the Contractor shall be responsible for the following.

Contractor Responsibilities

3.1.1 Technical Performance

In accordance with this SOW, BSA technical specification EIC-DET-SPC-021, and all referenced documents, the Contractor shall furnish all equipment, materials, tools, facilities, and labor to perform the work necessary to manufacture and test the Absorber Steel Structure on time, in the required quantity. The Contractor shall ensure that the finished product meets the performance parameters and criteria in accordance with BSA specification EIC-DET-SPC-021 and all other referenced documents. Failure to provide Steel Absorber Structures that satisfy the technical specifications outlined in EIC-DET-SPC-021 and all referenced documents will result in replacement of Steel Absorber Structure at the cost of the Contractor.

3.1.2 Tooling/Fixtures/Test Equipment

The Contractor shall be responsible for supplying all materials, including (but not limited to) the construction of all tools, jigs, fixtures, and test equipment required to meet the requirements of this SOW and specification.

3.1.3 Materials

The Contractor shall have an effective storage and age control system for items where acceptability is limited by the age or manner of storage of the item. Storage in a dry area and shipment in weatherproof containers are required.

Manufacturing Requirements

3.2.1 Detailed Analysis Requirements

The Contractor shall describe the methods and equipment to be used to control the dimensions of all parts and the assembled (electron-welded) steel absorber module.

3.2.2 Approval to Proceed

The approval to proceed shall be granted in writing by BSA, based on the results of the tests with first article modules, carried out at Oak Ridge National Laboratory (ORNL). For this purpose, five (5) steel absorber modules of type 8M shall be provided to ORNL.

3.2.3 Manufacturing, Inspection and Test Requirements

All absorber plates and casing parts shall be manufactured according to geometric tolerances in the technical drawings. The material chemical composition and magnetic properties shall match the technical specification EIC-DET-SPC-021. The fully electron-welded modules shall be tested for dimensions and tolerance compliance.

3.2.4 Acceptance Test Procedures (ATP)

The Contractor shall provide an ATP that is in accordance with this SOW, the specification, and all reference documents noted herein. The ATP must be approved in writing by BSA prior to use. The ATP shall ensure that all test requirements as defined in the specification are achieved.

Site acceptance testing at ORNL will include a complete characterization according to the ATP of all delivered complete modules. Modules which fail the requirements as specified in EIC-DET-SPC-021 will be returned to the Contractor for replacement.

Management

3.3.1 Program Plan

Within four (4) weeks after award of Contract, the Contractor shall deliver a detailed program plan which includes a milestone schedule defining the manufacturing, inspection, and testing phases in sufficient detail to allow regularly scheduled progress monitoring.

3.3.2 Progress Communications

Within four (4) weeks after award of Contract, bi-weekly program technical and progress telecommunications and/or meetings between the Contractor and BSA shall be held at a mutually scheduled time. The discussions shall include the Contractor’s progress, technical and contractual questions, presentations of analysis or testing results, design reviews, value engineering, troubleshooting, material status, tooling status, resources, and manufacturing issues.

3.3.3 Manufacturing/Inspection/Test Plan

A Manufacturing/Inspection/Test plan shall be developed which identifies the manufacturing processes required to complete all efforts as identified in this SOW. The plan shall be submitted for review and approval by BSA within four (4) weeks after award of Contract. The plan shall include manufacturing, inspection, and test steps.

The plan may be a single document or may make use of existing travelers or other suitable planning and control documents. It shall address the Material Requirements Planning (MRP), and at a minimum include manufacturing, inspection, and test steps including identification of critical manufacturing operations and parts/subassemblies showing integrated flow into the end item(s).

If the Contractor does not have an MRP system in place, then details for purchasing all raw materials, shop loading (by work center), and a schedule for manufacturing all components and assemblies through packaging and shipping shall be provided by the Contractor.

3.3.4 Performance Reporting

Throughout the life of the Contract, the Contractor shall supply a written report by the fifth of every month to the BSA Technical Representative and Contractual Representative clearly detailing progress through the prior month with respect to the program. This shall include milestone charts, detailed progress, open items, problems, recommended solutions, and risk mitigation.

3.3.5 “Witness” Points BSA reserves the right, after review of the Contractor Manufacturing/Inspection/Test Plan, to designate selected manufacturing, inspection, and/or test operations as “witness” points. The Contractor shall provide BSA with ten (10) working days’ notice in advance of such witness points during the manufacturing and test cycle.

1. Documentation and Data Management

3.4.1 Report/Documentation Format

a. All reports submitted shall include an introduction, body of the documents, and a conclusion. Large documents shall include a table of contents. For calculations, equations shall be shown with values defined for each variable so the analysis can be reviewed. Diagrams shall be included for clarity and labels shall be consistent with design drawings for specific items.

b. All documentation provided by the Contractor shall be in English.

c. The Contractor shall provide an electronic copy (BSA-identified FTP, DVD or USB data storage device) of all documentation required by this SOW. Contractor manufacturing Computer-Aided Design files of all components and assemblies shall be in one of these formats: STP, SAT, IGES, IAM, or IPT.

3.4.2 End Item Documentation Package

The Contractor shall provide with the End Item documentation package an electronic copy as well as three (3) physical copies of the following documentation in accordance with the schedule set forth in this SOW. The End Item documentation package shall consist of all documentation identified in this SOW and include the following:

a. Manufacturing Travelers: Manufacturing Travelers that include documentation of visual and dimensional inspections, materials, cleaning procedures, vacuum bake-outs, etc. shall be provided.

b. Final Inspection and Test Reports: Final test reports of all required or necessary inspections, examinations, and tests, properly validated by the Contractor’s authorized personnel shall be recorded and compiled in a measurement and test report and be supplied to BSA.

c. A listing of the delivered items, using a unique parts list or other such means of positive identification.

d. Material Certificates: Copies of material test reports for specified materials, showing physical and chemical properties, including permeability measurements of the magnetic steel.

e. Nonconformance Reports: Nonconformance reports identified as “rework / repair” or “use-as-is” shall be provided.

f. Certificate of Conformance The Contractor shall provide a Certificate of Conformance that certifies the following:

· Materials used are those which have been specified by BSA, and the items delivered were produced from materials for which the Contractor has on file, reports of chemical or physical analysis, or any other equivalent evidence of conformance.

· Processes used in the fabrication of items delivered were in compliance with the SOW or BSA-approved procedures or specifications.

· The items as delivered comply with all applicable specifications, and other requirements of the procurement documentation.

3.4.3 Records

The Contractor shall retain objective evidence, including records, of the inspections and tests performed in the course of manufacturing, testing, inspecting, preserving, packaging, and preparation for shipment of procured items. These records shall be made available to BSA for review upon request. These records shall be maintained for a minimum of three (3) years, unless otherwise specified in the procurement documentation, after the completion of the Purchase Order (PO)/Contract.

Marking and Serialization Where labeling is required, the position of serialization and/or labeling of the identification number/nameplate shall be agreed upon between the Contractor and BSA prior to acceptance of the final design. All completed modules shall have identifiable unique labeling to ease tracking of components.

2 QUALITY ASSURANCE

Quality System and Facility Access The Contractor shall maintain and apply an effective and documented quality assurance system for the design, manufacture, and testing of all equipment provided. The system shall meet the requirements of the ISO-9001 Standard, “Quality Management Systems Requirements”, and shall provide the processes to ensure that each component produced for acceptance conforms to the requirements of this document and the applicable technical documentation. The Contractor shall supply the necessary documentation to demonstrate this compliance. Post-award surveys may be required and shall be supported by the Contractor. In addition, BSA representatives will have access to the Contractor’s facility during agreed-upon fabrication, inspection and testing processes. The Contractor shall provide ten (10) working days’ notice in advanced of the agreed-upon witness points.

As set forth in BSA Form BNL-QA-101, “Brookhaven National Laboratory Supplier Quality Assurance Requirements,” as amended herein, forms a part of this statement of work. Specifically, this includes the following sections:

1, 2, 3, 3.1, 3.1.2, 3.2 to 3.22, 4.0, 4.1, 4.2, 4.3 ,4.4 as modified below, 4.4.1, 4.4.2, 4.4.3, 4.5 as modified below, 4.6, 4.7, 4.7.1, 4.7.3, 4.10, 4.10.1, 4.10.2, 4.10.3 4.10.4, 4.11, 4.13, 4.14, 4.15, 4.16, 4.18, 4.18,2, 4.18.3, 4.18.4, 4.19, 4.21, 4.22, 4.23, 4.24, and 4.39. With each Component delivered, the Contractor shall supply to BSA a Certificate of Conformance, in accordance with section 4.16 of BNL-QA-101.

Clause 4.4: Manufacturing / Inspection / Test Plan is modified as follows: Four weeks after receipt of order the supplier shall submit for the Buyer’s approval a Manufacturing / Inspection / Test Plan for the item(s) to be produced.

Clause 4.5: “Witness” Points, is modified as follows: The supplier shall provide BNL with ten (10) days’ notice in advance of reaching such witness points during the manufacturing and test cycle of each item.

Configuration Management The Contractor shall establish and maintain a configuration control system to ensure that all end items (LFHCal 8M and 4M modules) are of the proper configuration. The Contractor shall immediately notify the BSA Contractual Representative of any significant changes (those that may affect form, fit, function, reliability, safety, or interchangeability) in design, fabrication methods, material (including magnetic properties) or processing. Records verifying the configuration of each item shall be maintained by the Contractor for a minimum of five (5) years from the date of acceptance of the equipment by BSA.

For changes in configuration, a request for change approval shall be submitted to BSA for consideration. Changes in configuration may be made by the Contractor only with the written approval of BSA.

Responsibility for Subcontractor It is the responsibility of the Contractor to flow down and impose applicable technical and quality assurance requirements upon their contractors and subcontractors. BSA reserves the right to disapprove, in writing, any contractor or subcontractor.

Responsibility for Conformance The Contractor is responsible to provide items which conform to the requirements of the PO/Contract regardless of any assessments, surveillances, inspections and/or tests by BSA or its representatives at either the Contractor’s or BSA’s facility. The Contractor is responsible for notifying the BSA Contractual Representative of any recalls or alerts associated with this PO/Contract.

Measuring and Test Equipment (M&TE) Calibration The Contractor shall calibrate any M&TE used in the fulfillment of the PO/Contract requirements against certified standards that are traceable to national standards such as the National Institute of Standards and Technology (NIST), or an international standard, or a physical constant. The Contractor shall notify BSA of any condition found during the calibration, servicing or repair of measuring and test equipment that can affect the end item requirements.

Inspections and Test Requirements Unless otherwise specified in the PO/Contract, the Contractor shall be responsible for the performance of all inspections and tests specified herein. Except as otherwise specified in the PO/Contract, the Contractor shall utilize facilities suitable for the performance of the inspection and test requirements, specified herein, which are acceptable to BSA. BSA reserves the right to re-perform any of the inspections and/or tests set forth in this document or referenced specifications where deemed necessary to ensure that Equipment conforms to prescribed requirements at no cost to the Contractor. BSA and/or their representative shall have the option to witness all of the tests defined in this SOW.

4.6.1 Acceptance Testing

The modules shall be tested by the Contractor at the Contractor’s facility, the Contractor’s subcontractor’s facility, or a pre-approved BSA collaborator prior to shipment, using an ATP (as noted in Section 3.2.2) generated by the Contractor and approved in writing by BSA. BSA or its designee retains the right to witness all testing. Final acceptance of the units shall take place following the successful completion of final testing at ORNL. The time period for the final testing at ORNL shall be within 90 days after receipt of the units at ORNL.

4.6.2 Pre-Production Unit Acceptance

The Contractor shall provide pre-production units built to the specification for evaluation and testing at ORNL. BSA’s acceptance of pre-production unit(s) is required prior to the production run. The pre-production unit(s) shall be identified as such, including the PO number/Contract, part number, and part name.

4.6.3 Approval for Production

After the BSA Technical Representative’s acceptance of the pre-production unit(s), all of the remaining units required by the PO/Contract shall be produced by the Contractor and the Contractor’s suppliers using the same design, materials, processes, methods and tooling that were used to manufacture the approved pre-production unit(s). Any changes must have prior written approval from BSA Technical Representative and BSA Contract Specialist and may require a contractual modification. The Contractor should incorporate all of the costs related to design of the complete LFHCal modules, design and production planning, and production tooling and facilities into the pre-production unit cost. If production of the LFHCal modules is not approved by BSA, there shall be no further cost to BSA.

Repairs If failures occur or repairs are required to an assembly or any component during manufacturing or testing that affects form, fit, function, reliability, safety, or interchangeability the process shall stop and BSA shall be immediately notified. Failure to provide complete LFHCal modules that satisfy the technical specifications outlined in EIC-DET-SPC-021 and all referenced documents will result in replacement of modules at the cost of the Contractor. BSA at their discretion may ask for retesting, additional review and evaluation to determine root causes, analyses of failure modes(s) or proposals for repair. Proposals for repair shall include adequate information for evaluating the repair, testing the effectiveness of the repair, and methods to prevent damage to the existing work. No proposed repair shall be initiated without approval of BSA. No repair shall be considered successfully accomplished without inspection and written approval by BSA. All repairs shall be at the expense of the Contractor. In addition, the Contractor shall not use nonconforming materials via use-as-is disposition without written approval of BSA.

Failure Reporting, Analysis and Corrective Action The Contractor shall maintain a failure reporting, analysis, and corrective action system which shall, at a minimum, evaluate, analyze, and correct failures occurring during end-item acceptance testing and inspection. The results of all failure evaluations and analyses shall be documented and available for review by the BSA Contractual Representative.

DELIVERABLES

The Contractor shall supply the following:

Item
Deliverable
Due
BSA Approval
1
Program Plan
Four (4) weeks after award of Contract
Yes
2
Manufacturing/Inspection/Test Plan
Four (4) weeks after award of Contract
Yes
3
Acceptance Test Procedure (ATP)
Prior to first use
Yes
4
Delivery of Pre-Production Units
As set forth in schedule, Section 6
Yes
5
Pre-Production Units End-Item Documentation
As set forth in schedule, Section 6
Yes
6
Delivery of LFHCal modules
As set forth in schedule, Section 6
Yes
7
End Item Documentation
As set forth in schedule, Section 6
Yes

SCHEDULE

The following schedule is for planning purposes only. Schedule requirements set forth in the Contract will take precedence.

Milestone
Calendar weeks (maximum) after award
Delivery of five (5) pre-production units
10
End item documentation, pre-production units
10
BSA Evaluation of pre-production units
16
Delivery of 8M modules (batch 1), 645 modules
52
End item documentation (batch 1)
52
Delivery of 8M modules (batch 2), 200 modules (Option)
78
End item documentation (batch 2) (Option)
78
Delivery of 8M modules (batch 3), 216 modules (Option)
104
End item documentation (batch 3) (Option)
104
Delivery of 4M modules (batch 4), 72 modules (Option)
130
End item documentation (batch 4) (Option)
130

VALUE ENGINEERING

The Contractor is encouraged to make recommendations for changes that might lead to an improvement in performance, reliability, quality, safety, or reduction in cost. Simplicity in operation, ease of maintenance, and an improvement in the performance and reliability of the specific functions beyond the requirements of this specification are objectives which shall be considered in the production. Where it appears a substantial improvement in simplicity of design, performance, ease of maintenance or reliability will result from the use of materials, parts and processes other than those specified, it is desirable that their use be investigated. When investigations point to advantages that may be realized, the recommendation for change shall be presented to BSA for review.

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