ML16111A420

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Part 21 Report No. P21-04302015, Rev. 1 Regarding Potentially Unqualified Component in Certain Allen Bradley Timing Relays, Per Browns Ferry, Ginna, Millstone, Nine Mile Point, North Anna, Ft. Calhoun, Perry, River Bend, South Texas Project
ML16111A420
Person / Time
Site: Millstone, Browns Ferry, Nine Mile Point, Perry, Saint Lucie, North Anna, River Bend, Ginna, South Texas, Fort Calhoun  Constellation icon.png
Issue date: 04/08/2016
From: Bolt T
AZZ Incorporated, Nuclear Logistics
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
P21-04302015, Rev. 1
Download: ML16111A420 (9)
v • d • e


Text

0410812016 U.S. Nuclear Regulatory Commission Operations Center Event Report Part 21 (PAR)

Event#

Rep Org: AZZ/NLI NUCLEAR LOGISTICS, INC Notification Date I Time: 05/01/2015 13:32 Supplier: ALLEN BRADLEY Event Date I Time: 04/30/2015 Last Modification: 04/08/2016 Region: 4 Docket#:

City: Fort Worth Agreement State:

Yes County:

License#:

State: TX NRC Notified by: TRACY BOLT Notifications: MEL GRAY HQ Ops Officer: DANIEL MILLS FRANK EHRHARDT Emergency Class: NON EMERGENCY ROBERT ORLIKOWSKI 10 CFR Section:

GEOFFREY MILLER 21.21 (d)(3)(i)

DEFECTS AND NONCOMPLIANCE PART 21/50.55 REACTORS POTENTIALLY UNQUALIFIED COMPONENT IN CERTAIN ALLEN BRADLEY TIMING RELAYS The following is an excerpt from a document received from the licensee via email:

"Report of potential 10 CFR Part 21, Allen Bradley Timing Relay Model 700RTC "Pursuant to 1 O CFR 21.21 (d)(3)@, AZZ/NLI is providing written-notification of the identification of a potential failure to comply.

Pagel 51030*

(EDT)

(CDT)

R1DO R2DO R3DO R4DO EMAIL "On the basis of our evaluation, it is determined that AZZ/NLI does not have sufficient information to determine if the subject condition would, or has, created a Substantial Safety Hazard or would have created a Technical Specification Safety Limit violation as it relates to the subject plant applications.

"The specific part which fails to comply or contains a defect:

"As of 2009-2010, Allen Bradley relays base model 700RTC, contain an unevaluated CPLD (Complex Programmable Logic Device). This was an unpublished design change that was implemented to replace an obsolete integrated circuit chip. The undocumented design change did not result in a part number change from Allen-Bradley. There was no change to the appearance of the relay that would identify any design changes were made to the relay configuration. Therefore, NLI qualification/dedication of the relays after 2009 have not included additional testing for the new CPLD component.

"The timing relay model 700RTC has been dedicated/qualified for multiple applications for various plants.

"Between 2009-201 o Allen Bradley made a design change without changing the part number of the commercial

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0410812016 U.S. Nuclear Regulatory Commission Operations Center Event Report Page 2 relay or providing any documented evidence of a design change. The manufacturer specification data sheets maintain the classification that the relays are 'solid state', which would imply that there are no digital devices installed in the relay. However, after inspection of the internals of the timing relay (Figure 2), it has been identified that the unit does contain a CPLD which meets the definition of a digital device under the guidance of NEI 01-01."

Potentially affected plants include Browns Ferry, Ginna, Millstone, Nine Mile Point, North Anna, Ft. Calhoun, Perry, River Bend, South Texas Project, and St. Lucie.

  • AZZ/NLI Nuclear Logistics provided additional information regarding Part 21 Report No: P21-04302015, Rev. 1.

Notified R1 DO (Rogge), R2DO (Nease), R3DO(Skokowski), R4DO (Kellar), and PART 21/50.55 REACTORS via email.

64/0812016 16:41 Date: April 8, 2016 To:

FAX (301) 816-5151 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 From:

Tracy Bolt Director of Quality Assurance AZZjNLI Nuclear Logistics 7 410 Pebble Drive Fort Worth, Texas 76118 UPDATE - Report of potential 1 OCFR Part 21, Allen Bradley Timing Relay Model 700RTC Report No: P2t.. Q4302015, Rev. 1 Previous NRC Event 51030 Previous Accession No: :ML15134A016 Total pages including this page: 1 NUCLEAR LOGISTICS INC.

P.001/007 www.azz.com 7410 Pebble Drive Fort Worth, Texas 76*118 800.448.4124 Phor1e 8'17.590.. 0484 Fax

0410812016 16:41 Date: April 8, 2016 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Part 21 Report No: P21~04302015, Rev. 1

!,FAX)

Pi!:AZZ

Subject:

Update.. Report of potential 10CFR Part 21, Allen Bradley Timing Relay Model 700RTC-NRC Event Number 51030, Accession Number ML15134A016 p.0021001'.

N LI' PjJrsuant to IOCFR 21.21 (d) (3) (ii), AZZINLI is providing written notification of the identification of a potential failure to comply.

On the basis of our evaluation, it is determined that AZZINLI does not have sufficient information to determine if the subject condition would, or has, created a Substantial Safety Hazard or would have created a Technical Specification Safety Limit violation as it relates to the subject plant applications.

I The following information is required per 1 OCFR 21.21 ( d) ( 4 ).

(i) Name and address of the individual or individuals informing the Commission.

Tracy Bolt, Director of Quality Assurance Nuclear Logistics, Inc 7410 Pebble Drive Ft. Worth, Tx 76118 (ii) Identification of the facility, activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect.

The specific part which fails to comply or contains a defect:

As of2009-2010, Allen Bradley relays base model 700RTC, contain an unevaluated CPLD (Complex Programmable Logic Device). This was an unpublished design change that was *implemented to replace an obsolete integrated circuit chip. The undocumented design change did not result in a part nwnber change from AllenwBradley. There was no change to the appearance of the relay that would identify any design changes were made to the relay configuration.

The timing relay model 700RTC has been dedicated/qualified for multiple applications for various plants.

NUCLEAR LOGISTICS INC.

Page 1 of6 www.azz.com 7410 Pebble Drive Fort Worth, Texas 76'118 800.448.4124 Phone 817_590.0484 Fax

04/08/2b16 16:41 P.003/007 (iii)

Identification of the firm constructing or supplying the basic component which fails to comply or contains a defect.

NLI procured the commercial grade relays, dedicated, qualified and supplied the subject relays as Safety Related.

(Iv)

Nature of defect or failure to comply and the safety har.ard which is created or could be created by such defect or failure to comply.

Between 2009-2010~ Allen Bradley made a design change without changing the part number of the commercial relay or providing any documented evidence of a design change. The manufacturer specification data sheets maintain the classification that the relays are "solid state", which would imply that there are no digital devices installed in the relay. However, after inspection of the internals of the timing relay (Figure 2), it has been identified that the unit does contain a CPLD which meets the definition of a digital device under the guidance ofNEl 01-0 I. See Figures 1 and 2 below:

Figure 1-Original qualified design (prior to 2009).

Relays supplied prior to 2009 are not affected by this issue.

Part 21 Report No: P21-04302015, Rev. 1 Page 2 of6

04/08/2016 16:41 p.604/007 *.

Figure 2 - New design circuit board and CPLD that replaced the original component.

(v)

The date on which the Information of 111uch defect or failure to comply was obtained.

On April 27, 2015, enough information was gathered from the evaluations being perfonned to detennine the reportability of the failure to comply that is the root cause for the event.

Part 21 Report No: P21-04302015, Rev. 1 Page 3 of6

U4iOBl2b16 16:41 P.005/007

('1i)

In the case of a basic component which contains a defect or falls to eomply, the number and location of these components in use at, supplied for being supiilied for, or may be supplied fort manufactured or being manufactured for one or more facilities or activities subject to the regulations in this iiart.

Relays that have been procured and dedicated from 2009 to present are identified below.

Plant Name Purchase order Browns Ferry 72923-1 Ginna Station 6617899 Grand Gulf 10304816 Grand Gulf 10400205 Invensys 4540216542 KHNP Y12-0292-010 Lun2I11en 874941 IE007CO Millstone 45735761 Millstone 45735761 Nine Mile Point 530734 North Anna 70239037 North Anna 70239037 North Anna 70239037 OPPD Ft Calhoun 155213 OPPD Ft Calhoun 163495 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 177878 OPPD Ft Calhoun 182681 OPPD Ft Calhoun 187625 Peny Station 45354401 River Bend Station 10349942 River Bend Station 10362573 River Bend Station 10378904 South Texas Project 134783 Serial Number 29760-001-00003 51475-001-00001 and-00002, 52656Kl-01-0001 34182-001-00001 56319-001-00001 39228-001-00001 thru-00017, 39228-001-00158 thru 39228-001-00166, 39228-001-00170 thru 39228~001-00177 39407-001-00001 thru-00008, 39407-002-00001 thru -

00005 38486-001-00001and-00002,38486-002-00001 31998Kl-01-0001 31391-001-00001 63245-001-00001 thru -00018 55133-001-00001 &-00002 39602-001-00001 and-00002t 3.9602-002-00001 thru -.

00003 40033-001-00001 and 40033-001-00002, 40033-002-00001 thru-00003 33846-001-00001 thru -00009, 33846-001-00011 thm 33846-001-00015, 33846-002-00002 & -00003 35941-001-00001 thru -00004 35891Kl~Ol-0001 thru -0005 36888-001-00001 *..00003 thru -00005

. 36888K2-0I-0001 39194-001-00001 thru -00006 40743-001-00001 thru "00003, 40743-002-00001 51477-001-00001 thru -00004 33357-001-00001 thru -00003 38585-001-00001 thru -00004 40077-001-00001 51627-001-00001 33750-001-00001 & -00002 Part 21 Report No: P21-04302015, Rev. 1 Page 4 of6

04/08/2016 16:42 P.066/007:..

South Texas PrQiect 147962 37204-001-00001 thru -00006 South Texas Project 154172 51592-001-00001 thru -00004 South Texas Project 171193 57894-001-00001 thtu-00006 St Lucie Bechtel PO: 25486-974-38549-001-00002 thru -00005 FPA-EMROuOOOOl (vii)

The corrective action whieh has been, is being, or will be taken; the name of the individual or organimtion responsible for the action; and the length of time that bas been or will be taken to complete tbe action.

The relays that are currently in stock at NLI have been placed on hold until after the units have been determined to be qualified for the specific application. NLI has completed the EMC qualification testing per the requirements of EPRI TR-102323 Rev. 3 for the following tests. as applicable: CE 101, CE102, RElOl, RE102, RSlOl, RS103, CSlOl, CSl 14, CSl 15 and CSl 16.

The results were satisfactory with exception of the following condition: During Conducted Susceptibility CS 114 onto the power lines, with the timing circuit in operationt the timing contacts exhibited chatter in the range of2.6 MHz to 20.3 MHz. The unit requires a ferrite to be installed onto the input power lines of the relay with 3 turns through the ferrite core. In this modified configuration, the relay was not susceptible to Conducted Susceptibility and successfully passed the required test per CS114.

In addition to the EMC testing that was performed, the Verification and Validation I Dedication activities for the digital device was also completed. The results of the dedication activity are contained in NL! Verification and Validation/Dedication report VVR-700RTC-Ol, Rev. 1. The results of the V&V/dedication activity are satisfactory. The finnware version verified is the only version that has been released since the change was implemented.

Part 21 Report No: P21-04302015~ Rev. 1 Page 5 of6

0'4~0B/f016 16:42 P.007/007 (viii)

Any advice related to the defect or failure to comply about the :facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.

The functions of the relays supplied by NLI were tested for the following critical characteristics:

Pick-up at rated voltage Drop-out when the voltage is removed Pick-up at degraded voltage Over-Voltage operation Insulation resistance Off delay settings are adjustable from 2-120 seconds Pick-up voltage Drop-out voltage Dimensions and Configuration The relays are dedicated for generic application usage in timing applications. The specific plant application(s) is unknown by NLI. The EMC qualification of the relay is dependent on the installed configuration and location in the plant. The plant should evaluate whether the installed relays are subjected to the specific EMIIRFI condition Conducted Susceptibility CS 114 between the frequencies of2.6 MHz to 20.3 MHz identified above.

Please contact me with any questions or comments.

Si~~

Tuey&*'

Director of Quality Assurance Part 21 Report No: P21-04302015, Rev. 1 Page 6 of6

0410812016 U.S. Nuclear Regulatory Commission Operations Center Event Report Part 21 (PAR)

Event#

Rep Org: AZZ/NLI NUCLEAR LOGISTICS, INC Notification Date I Time: 05/01/2015 13:32 Supplier: ALLEN BRADLEY Event Date I Time: 04/30/2015 Last Modification: 04/08/2016 Region: 4 Docket#:

City: Fort Worth Agreement State:

Yes County:

License#:

State: TX NRC Notified by: TRACY BOLT Notifications: MEL GRAY HQ Ops Officer: DANIEL MILLS FRANK EHRHARDT Emergency Class: NON EMERGENCY ROBERT ORLIKOWSKI 10 CFR Section:

GEOFFREY MILLER 21.21 (d)(3)(i)

DEFECTS AND NONCOMPLIANCE PART 21/50.55 REACTORS POTENTIALLY UNQUALIFIED COMPONENT IN CERTAIN ALLEN BRADLEY TIMING RELAYS The following is an excerpt from a document received from the licensee via email:

"Report of potential 10 CFR Part 21, Allen Bradley Timing Relay Model 700RTC "Pursuant to 1 O CFR 21.21 (d)(3)@, AZZ/NLI is providing written-notification of the identification of a potential failure to comply.

Pagel 51030*

(EDT)

(CDT)

R1DO R2DO R3DO R4DO EMAIL "On the basis of our evaluation, it is determined that AZZ/NLI does not have sufficient information to determine if the subject condition would, or has, created a Substantial Safety Hazard or would have created a Technical Specification Safety Limit violation as it relates to the subject plant applications.

"The specific part which fails to comply or contains a defect:

"As of 2009-2010, Allen Bradley relays base model 700RTC, contain an unevaluated CPLD (Complex Programmable Logic Device). This was an unpublished design change that was implemented to replace an obsolete integrated circuit chip. The undocumented design change did not result in a part number change from Allen-Bradley. There was no change to the appearance of the relay that would identify any design changes were made to the relay configuration. Therefore, NLI qualification/dedication of the relays after 2009 have not included additional testing for the new CPLD component.

"The timing relay model 700RTC has been dedicated/qualified for multiple applications for various plants.

"Between 2009-201 o Allen Bradley made a design change without changing the part number of the commercial

/ q

/.: [

-;v ~R~

  • ¢,

0410812016 U.S. Nuclear Regulatory Commission Operations Center Event Report Page 2 relay or providing any documented evidence of a design change. The manufacturer specification data sheets maintain the classification that the relays are 'solid state', which would imply that there are no digital devices installed in the relay. However, after inspection of the internals of the timing relay (Figure 2), it has been identified that the unit does contain a CPLD which meets the definition of a digital device under the guidance of NEI 01-01."

Potentially affected plants include Browns Ferry, Ginna, Millstone, Nine Mile Point, North Anna, Ft. Calhoun, Perry, River Bend, South Texas Project, and St. Lucie.

  • AZZ/NLI Nuclear Logistics provided additional information regarding Part 21 Report No: P21-04302015, Rev. 1.

Notified R1 DO (Rogge), R2DO (Nease), R3DO(Skokowski), R4DO (Kellar), and PART 21/50.55 REACTORS via email.

64/0812016 16:41 Date: April 8, 2016 To:

FAX (301) 816-5151 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 From:

Tracy Bolt Director of Quality Assurance AZZjNLI Nuclear Logistics 7 410 Pebble Drive Fort Worth, Texas 76118 UPDATE - Report of potential 1 OCFR Part 21, Allen Bradley Timing Relay Model 700RTC Report No: P2t.. Q4302015, Rev. 1 Previous NRC Event 51030 Previous Accession No: :ML15134A016 Total pages including this page: 1 NUCLEAR LOGISTICS INC.

P.001/007 www.azz.com 7410 Pebble Drive Fort Worth, Texas 76*118 800.448.4124 Phor1e 8'17.590.. 0484 Fax

0410812016 16:41 Date: April 8, 2016 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Part 21 Report No: P21~04302015, Rev. 1

!,FAX)

Pi!:AZZ

Subject:

Update.. Report of potential 10CFR Part 21, Allen Bradley Timing Relay Model 700RTC-NRC Event Number 51030, Accession Number ML15134A016 p.0021001'.

N LI' PjJrsuant to IOCFR 21.21 (d) (3) (ii), AZZINLI is providing written notification of the identification of a potential failure to comply.

On the basis of our evaluation, it is determined that AZZINLI does not have sufficient information to determine if the subject condition would, or has, created a Substantial Safety Hazard or would have created a Technical Specification Safety Limit violation as it relates to the subject plant applications.

I The following information is required per 1 OCFR 21.21 ( d) ( 4 ).

(i) Name and address of the individual or individuals informing the Commission.

Tracy Bolt, Director of Quality Assurance Nuclear Logistics, Inc 7410 Pebble Drive Ft. Worth, Tx 76118 (ii) Identification of the facility, activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect.

The specific part which fails to comply or contains a defect:

As of2009-2010, Allen Bradley relays base model 700RTC, contain an unevaluated CPLD (Complex Programmable Logic Device). This was an unpublished design change that was *implemented to replace an obsolete integrated circuit chip. The undocumented design change did not result in a part nwnber change from AllenwBradley. There was no change to the appearance of the relay that would identify any design changes were made to the relay configuration.

The timing relay model 700RTC has been dedicated/qualified for multiple applications for various plants.

NUCLEAR LOGISTICS INC.

Page 1 of6 www.azz.com 7410 Pebble Drive Fort Worth, Texas 76'118 800.448.4124 Phone 817_590.0484 Fax

04/08/2b16 16:41 P.003/007 (iii)

Identification of the firm constructing or supplying the basic component which fails to comply or contains a defect.

NLI procured the commercial grade relays, dedicated, qualified and supplied the subject relays as Safety Related.

(Iv)

Nature of defect or failure to comply and the safety har.ard which is created or could be created by such defect or failure to comply.

Between 2009-2010~ Allen Bradley made a design change without changing the part number of the commercial relay or providing any documented evidence of a design change. The manufacturer specification data sheets maintain the classification that the relays are "solid state", which would imply that there are no digital devices installed in the relay. However, after inspection of the internals of the timing relay (Figure 2), it has been identified that the unit does contain a CPLD which meets the definition of a digital device under the guidance ofNEl 01-0 I. See Figures 1 and 2 below:

Figure 1-Original qualified design (prior to 2009).

Relays supplied prior to 2009 are not affected by this issue.

Part 21 Report No: P21-04302015, Rev. 1 Page 2 of6

04/08/2016 16:41 p.604/007 *.

Figure 2 - New design circuit board and CPLD that replaced the original component.

(v)

The date on which the Information of 111uch defect or failure to comply was obtained.

On April 27, 2015, enough information was gathered from the evaluations being perfonned to detennine the reportability of the failure to comply that is the root cause for the event.

Part 21 Report No: P21-04302015, Rev. 1 Page 3 of6

U4iOBl2b16 16:41 P.005/007

('1i)

In the case of a basic component which contains a defect or falls to eomply, the number and location of these components in use at, supplied for being supiilied for, or may be supplied fort manufactured or being manufactured for one or more facilities or activities subject to the regulations in this iiart.

Relays that have been procured and dedicated from 2009 to present are identified below.

Plant Name Purchase order Browns Ferry 72923-1 Ginna Station 6617899 Grand Gulf 10304816 Grand Gulf 10400205 Invensys 4540216542 KHNP Y12-0292-010 Lun2I11en 874941 IE007CO Millstone 45735761 Millstone 45735761 Nine Mile Point 530734 North Anna 70239037 North Anna 70239037 North Anna 70239037 OPPD Ft Calhoun 155213 OPPD Ft Calhoun 163495 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 177878 OPPD Ft Calhoun 182681 OPPD Ft Calhoun 187625 Peny Station 45354401 River Bend Station 10349942 River Bend Station 10362573 River Bend Station 10378904 South Texas Project 134783 Serial Number 29760-001-00003 51475-001-00001 and-00002, 52656Kl-01-0001 34182-001-00001 56319-001-00001 39228-001-00001 thru-00017, 39228-001-00158 thru 39228-001-00166, 39228-001-00170 thru 39228~001-00177 39407-001-00001 thru-00008, 39407-002-00001 thru -

00005 38486-001-00001and-00002,38486-002-00001 31998Kl-01-0001 31391-001-00001 63245-001-00001 thru -00018 55133-001-00001 &-00002 39602-001-00001 and-00002t 3.9602-002-00001 thru -.

00003 40033-001-00001 and 40033-001-00002, 40033-002-00001 thru-00003 33846-001-00001 thru -00009, 33846-001-00011 thm 33846-001-00015, 33846-002-00002 & -00003 35941-001-00001 thru -00004 35891Kl~Ol-0001 thru -0005 36888-001-00001 *..00003 thru -00005

. 36888K2-0I-0001 39194-001-00001 thru -00006 40743-001-00001 thru "00003, 40743-002-00001 51477-001-00001 thru -00004 33357-001-00001 thru -00003 38585-001-00001 thru -00004 40077-001-00001 51627-001-00001 33750-001-00001 & -00002 Part 21 Report No: P21-04302015, Rev. 1 Page 4 of6

04/08/2016 16:42 P.066/007:..

South Texas PrQiect 147962 37204-001-00001 thru -00006 South Texas Project 154172 51592-001-00001 thru -00004 South Texas Project 171193 57894-001-00001 thtu-00006 St Lucie Bechtel PO: 25486-974-38549-001-00002 thru -00005 FPA-EMROuOOOOl (vii)

The corrective action whieh has been, is being, or will be taken; the name of the individual or organimtion responsible for the action; and the length of time that bas been or will be taken to complete tbe action.

The relays that are currently in stock at NLI have been placed on hold until after the units have been determined to be qualified for the specific application. NLI has completed the EMC qualification testing per the requirements of EPRI TR-102323 Rev. 3 for the following tests. as applicable: CE 101, CE102, RElOl, RE102, RSlOl, RS103, CSlOl, CSl 14, CSl 15 and CSl 16.

The results were satisfactory with exception of the following condition: During Conducted Susceptibility CS 114 onto the power lines, with the timing circuit in operationt the timing contacts exhibited chatter in the range of2.6 MHz to 20.3 MHz. The unit requires a ferrite to be installed onto the input power lines of the relay with 3 turns through the ferrite core. In this modified configuration, the relay was not susceptible to Conducted Susceptibility and successfully passed the required test per CS114.

In addition to the EMC testing that was performed, the Verification and Validation I Dedication activities for the digital device was also completed. The results of the dedication activity are contained in NL! Verification and Validation/Dedication report VVR-700RTC-Ol, Rev. 1. The results of the V&V/dedication activity are satisfactory. The finnware version verified is the only version that has been released since the change was implemented.

Part 21 Report No: P21-04302015~ Rev. 1 Page 5 of6

0'4~0B/f016 16:42 P.007/007 (viii)

Any advice related to the defect or failure to comply about the :facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.

The functions of the relays supplied by NLI were tested for the following critical characteristics:

Pick-up at rated voltage Drop-out when the voltage is removed Pick-up at degraded voltage Over-Voltage operation Insulation resistance Off delay settings are adjustable from 2-120 seconds Pick-up voltage Drop-out voltage Dimensions and Configuration The relays are dedicated for generic application usage in timing applications. The specific plant application(s) is unknown by NLI. The EMC qualification of the relay is dependent on the installed configuration and location in the plant. The plant should evaluate whether the installed relays are subjected to the specific EMIIRFI condition Conducted Susceptibility CS 114 between the frequencies of2.6 MHz to 20.3 MHz identified above.

Please contact me with any questions or comments.

Si~~

Tuey&*'

Director of Quality Assurance Part 21 Report No: P21-04302015, Rev. 1 Page 6 of6

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