C bent01

Design
Engineering
A Bentley White Paper
Hilmar Retief
product manager
AssetWise

www.bentley.com

Striving to maintain the nuclear design basis: What to look
for in an electronic design engineering solution

The Situation
When owner-operators first opened the doors to their newly constructed nuclear plants
years ago, many had no system for finding and retrieving their plants’ design basis
information. As a result, they had to spend huge sums of money to reconstitute their
respective plant’s design basis. Unfortunately, most of these efforts ended up in a
dusty back room, never to be seen again. Of course, to be efficient and safe, plant
configuration management must be maintained, and doing so effectively means the
plant design basis must be an active part of the design change process.
In the 1970s and ’80s, architectural firms created literally millions of pages of hard
copy documentation on the design bases of nuclear plants while under construction.
These documents contained valuable information, including plant configurations,
specifications, calculations, and drawings. In many cases owner-operators were not
given free and unrestricted access to these sources, but rather had to specifically
request and pay for the information.
The information the owner-operators received often was in fragmented pieces, stored
only on paper or in illegible proprietary formats. During and right after start-up, most
plant owner-operators could contact the design engineers who worked on the plant to
get information. Through this tribal knowledge, a second generation of engineers could
find and use the design basis information. But as time passed, this knowledge typically
degenerated, and nuclear plant owner-operators struggled to teach new engineers how
to find and use the design basis information.
One remedy many owner-operators used was to extract the pertinent information
and create their own applications to make the applicable design basis information
available. This ensured their plant configuration would be maintained and accessible
for personnel to use in everyday plant operation. As a result, almost every plant had its
own proprietary applications and repositories of information, spread across multiple
software platforms.
Finding and consolidating this information into a single focused dataset is complex and
labor-intensive. Moreover, it is extremely error prone and completely depends on the
consumer of the information to ensure that it is complete and accurate.
From a plant perspective, these factors create many ongoing enterprise information
management issues, including rework, project delays, and potential adverse findings
from industry regulatory agencies. While the information management revolution
is already in its second iteration, it isn’t really at the top of most plant operators’
priority lists. An industry oversight organization has found multiple areas for
improvement items, and the Nuclear Regulatory Commission (NRC) has identified
findings for various aspects relating to information accuracy and usage.

Design Engineering 2

Sometimes nuclear plant managers fail to see the forest for the trees. Day-to-day
information management challenges seem overwhelming, and the obvious strategy
of implementing a well-defined and managed enterprise information system is often
neglected. The main challenge is the ability to comprehensively manage changing
information throughout the facility’s lifecycle. The operational goal is to enable
engineers to easily access accurate, up-to-date design basis information and make
necessary document changes to maintain plant configuration. Superior enterprise
information management results in seamless business processes that support plant
personnel to effectively manage the facility.
This white paper focuses specifically on the design engineering process and how a
consolidated information management practice can increase efficiency, while reducing
rework due to field change notices (FCNs) and regulatory findings.
This information access challenge applies to various processes in the daily operation of
a nuclear plant, including the origination (training and qualification), creation, approval,
and closeout processes involved in design change packages (DCPs). DCPs define the
scope of work and consolidate the engineering products necessary to effect changes in
the physical plant, manage material equivalency, and apply administrative changes and
corrections. (Continued on page 4.)

Regulatory Agency Standards for Design Engineering

10CFR 50 Appendix B —
Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants
10CFR 50 Appendix B is the Code of Federal Regulations that establishes the Quality
requirements for various aspects of the Commercial Nuclear Power Program. Within
this regulation, Criterion III specifically addresses design control and includes the
following measures:
• Applicable regulatory requirements and the design basis must be correctly translated
into specifications, drawings, procedures, and instructions.
• Provisions must be included to assure that appropriate quality standards are
specified and included in design documents and that deviations from these standards
are controlled.
• A review and selection process must be put in place to identify suitable materials,
including parts, equipment, and processes that are essential to the safety-related
functions of the structures, systems, and components.
• Design interfaces must be identified and controlled, and coordinated among
participating design organizations. This includes establishing procedures among
participating design organizations for the review, approval, release, distribution,
and revision of documents involving design interfaces.


• Design control must include a process to verify or check the adequacy of designs,
either through design reviews, by the use of alternate or simplified calculational
methods, or by the performance of a suitable testing program. This verification process
may be completed by personnel from the same organization, but not by those who were
involved in the development of the original design.
• Design control should be applied to items including: reactor physics, stress, thermal,
hydraulic, and accident analyses; compatibility of materials; accessibility for inservice
inspection, maintenance, and repair; and delineation of acceptance criteria for
inspections and tests.
• Design changes, including field changes, must be subjected to design control
measures equivalent to those applied to the original design. They must also be
approved by the organization that performed the original design unless the applicant
designates another responsible organization.

ANSI N45.2.11 –
Developed by the American Society of Mechanical Engineers (ASME)
ANSI N45.2.11 is the primary industry standard most plants have adopted and
committed to, and discusses all aspects of the design control process in general detail
from developing the design inputs and functional requirements to the implementation
and closeout of the change. It discusses the documentation requirements and the
requirements of the business relationship between the plant and the many outside
organizations involved in the design process.

Design Engineering Regulations –
Even in today’s so-called Establishing the Goals of an Electronic System
information age where
powerful information Before the issuance of industry regulations, there was very little specific guidance
processing platforms related to the management of engineering changes. Even in today’s so-called
exist, an electronic design information age where powerful information processing platforms exist, an electronic
change process is almost design change process is almost unheard of. While many plant operators claim they
unheard of. conduct electronic design change packages, the information and processing of these
changes are fragmented, offering very little assistance to the design engineer
responsible for preparing, reviewing, and coordinating the impact of the design
change and performing the closeout process.
In most cases, drawing management, calculation revisions, system, structure
and component (SSC) changes, and the closeout process are contrasting business
processes, managed in isolation and by functionally separate users. Though nuclear
plant operators recognize this is a problem, they are continually hampered by
information that resides in hard copies, images, or in completely segregated
software applications.


Nuclear Software Tools
Literally hundreds of software tools exist to solve parts of the access-to-information
problem. They include 2D and 3D CAD or drawing management tools, document
content management tools, and work management tools. While a few SSC change
management tools are available, most focus on materials management processes
or manufacturing facilities. Some of these tools have been customized for nuclear
facilities, but with limited success. They try to address the fixed asset management
problems and related design engineering issues.
But tools for more complex engineering challenges are few and far between. Indeed,
proper modification package and cable management solutions are limited to two or
three commercially available tools and a flurry of home-grown applications.
While integration possibilities exist, these applications are designed to work in
Only sheer willpower isolation and any integration normally results in the duplication of information and/
and extremely rigorous or business processes. These information silos do little to alleviate the information
review and approval management problems described above. Only sheer willpower and extremely rigorous
processes can avoid review and approval processes can avoid engineering mistakes.
engineering mistakes.
The Design Engineering Change Process
The design engineering change process is not all that different from change processes
used in other industries. Essentially the process includes the following basic steps:
• Problem Identification and Resolution Process
»» Problem identification
»» Analysis
»» Deploying corrective and performance improvement actions
• Change Request
»» Change impact analysis and technical reviews
»» Scoping the problem and determining resource needs
• Change Disposition
»» Resource allocation
»» Design development and planning coordination
»» Review and approval
• Implementation
• Effectiveness reviews, closeout, and baseline
Note that this fairly simplistic change process doesn’t include more complex issues
like the effect of change, concurrent engineering, ongoing plant maintenance, and the
interaction between engineering design products, such as redline or markup drawings,


calculation change notices, and the as-built products. For the purposes of this white
paper, we will examine the simplified process, but the additional complexities found in
real-world situations only enhance the need for effective solutions.

Developing the Design Change Package
The design change package can be logically divided into three elements:
• Change request
• Change disposition
• Electronic workflow of the modification package and applicable changes that are
needed for the change disposition
In brief, the design change package follows a prescribed path. The need to use the
modification process at a nuclear plant is typically identified through actions needed in
the plant’s corrective action process or by work request documents generated by the
plant personnel or within the engineering department. These documents describe the
nature of the problem, its priority and any other applicable user-defined information.
The engineering department reviews these documents to confirm whether changes to
the plant are required. In addition to these initiating documents, a change request
summarizes the reason for the change.
Often, change requests define the scope of the proposed change. They are evaluated
The information is then by the engineering change board for budgetary concerns and other factors before the
available electronically change package is initiated. Other engineering products such as the written basis for
during troubleshooting and the acceptance of the change, program review documents, and reference documents
future design changes are then added after the engineering department approves the change request. It then
to aid in the research of becomes part of the change disposition. This compilation of information allows easier
problems in that area. access to relevant information and is submitted to an established workflow for review,
approval, coordination, and closeout. The information is then available electronically
during troubleshooting and future design changes to aid in the research of problems in
that area.

Change Request
The change request also has three key elements:
• The reasons for the change, mostly elevated through the corrective action process
or requests for information, and directed to the engineering department;
• The scope of the change, which includes identifying the affected documents,
systems, components, processes, and people;
• Change approval.


A critically important, though typically manual, part of the change request process
is identifying related components and documents that are indirectly affected by the
change, but that could significantly impact the modification. For most plant operators
and engineers this is an arduous and error-prone process of brute force research,
comprised of a combination of keyword and other database search techniques. The
search results often end up in another data silo, namely the modification summary
form, which is reviewed, approved, and filed away in a document management system.
The modification summary form is generally a paper-based form where engineers
capture information about the affected documents and components, as well as any
markups and change notices derived from it.

Manual vs. Electronic Design Change Process

Domain Experts /
Multipl Data Bases
u
Multiple Tacit Knowledge Remote Knowledge Sources

With a manual process engineers must
search through multiple silos of information,
Engineers including hard copy files.

Paper Archives
Collaboration
Resource Intensive Searches

With a robust electronic design change
process all relevant search information,
Multipl Data Bases
u
Multiple including hard copy masters, are
automatically identified and presented
by the application.

Remote Knowledge Sources

Electronic
Design Change
Domain Experts / Process
Tacit Knowledge Engineers

Collaboration

Paper Archives

Resource Intensive Searches


An electronic design change process automates and streamlines these actions, where
the affected and potentially affected components, documents, and processes are
identified through established relationships and made available as a comprehensive
change effects analysis with a click of a button. In this case the modification summary
form is a report rendered from previously captured and related information, which could
be stored away as a quality record.
Lastly, the electronic change request represents the entire population of as-built
documents, components, and equipment affected by the proposed modification. The
change request is then reviewed and approved electronically. The process generates an
electronic approval report, which contains all the information identified in the scope of
the change, the reviewers, and their electronic signatures.

Change Disposition
The change disposition
(also known as the The change disposition (also known as the modification package) represents the
modification package) collection of engineering products used by the field during the actual implementation
of the modification. These engineering products include construction drawings,
represents the collection
redlines, updated calculations, updated component configurations, new and updated
of engineering products
cable routes, and much more.
used by the field during the
actual implementation of Again, at most plants the creation, compilation, and approval of this change
the modification. disposition, or modification package, is a manual, mostly paper-based process.
Even if the documents end up in electronic form for the purpose of storing the quality
record, the process for creating them is primarily manual and the search tools
available are limited.
Clearly, an electronic design change process transforms this effort into a single,
simple, and streamlined electronic process. Using an electronic process fully automates
the creation of the change disposition, including the redlines (markups), updated
components (prototypes), calculations, and change notices. Moreover, a fully automated
process does not require engineers to print and manually mark up drawings (though
this is still an option). The software tool maintains the relationship between the
original drawing, the change package, and the markup document. The markup is
always available to anyone with the appropriate security access to view it, and to
collaborate and add value during the markup process.
Upon creation and collection of the necessary engineering products, the change
disposition is again sent for electronic review and approval with the same rigor and
detail as for the package itself.

Implementing an Electronic Design Change Process
The single most important factor for implementing an electronic design engineering
process is to resolve and avoid the information silo problem.
Information silos are often referred to as rogue databases, created and maintained by
individuals. They include innocent looking items like spreadsheets, Microsoft Access
databases, and even private copies of controlled documents and procedures. These
data sources are not controlled or verified, and are often the result of an inadequate


centralized information management system. Organizations can end up spending
millions to consolidate these data sources, but if information management is not
addressed from an enterprise perspective, the problem will return.
The effectiveness of an electronic design change process centers on the ability of the
software solution to assist in predicting immediate and latent effects of a change to
the configuration of the facility, making it critical that the software solution include
robust configuration management capabilities. The change effects analysis produced by
the software should include information about those documents, SSCs, processes, and
people that are directly affected by the change, as well as those business entities that
may be indirectly affected (see sidebar).

Change Impact Analysis: An Example
A change to a pipe might affect one or more drawings, the connected valve, as well as
one or more calculations.
In turn, a change to the calculation could affect other artifacts that don’t have anything
to do with the original pipe change.
Additionally, ongoing field work could affect the timing of the change and the
availability of the required resources necessary to implement the proposed change.
By implementing a software system that automatically identifies these elements engineers
can save thousands of man-hours in labor and significantly minimize the risk of error.

Change Package Scope
In most nuclear plants today, the scope of a design change process is chiefly documented
in an engineering summary form. This form contains a description of the proposed
change, rationale for why it should be executed, as well as a summary of the potential
impact of the change. While the form could be electronic, say in the shape of a web
form, the process of capturing the scope is separate from identifying and integrating
the information assets and physical items that will be affected by the proposed change.
To achieve a successful electronic design change process with configuration control, the
identification of the scope of change must be integrated into the design change process.
This will allow continuous, accurate reporting on the potential effects of the change, as
well as populate the design change package build process and package closeout.

Engineering Products
Engineering products, also referred to as modification documents, are those documents
and SSCs created as part of the design change process. For instance, drawings, which
are the most familiar, would include markup or redline drawings and drawing change
notices. Modification documents, especially markup drawings, are copies of the
original as-built drawing made during the creation of the engineering change package.
These markups are made by, or provided to, the design engineer and are used during


construction or plant modifications. Other modification documents, like change notices,
are documents that don’t represent a complete copy of the original, but rather a
fragment or a partial copy.

Change Package Implementation
Once engineering products, in the form of drawing redlines, updated calculations,
installation instructions, etc., have been created, reviewed, and approved, the change
package is ready for field implementation. This process varies from plant to plant, but
for the most part it is a manual process whereby clerks and/or engineers will print the
elements of the package and distribute the package to implementation coordinators.
The normal practice is to print most or all of the documents on multiple occasions—
the so-called ‘T-week’ cycle. The intent of this legacy process is to allow field
implementers and work planners to review the documents before the modifications
are made. This ensures that the revisions are still applicable and that no changes
that affect the implementation of the change package were made.
Again, this presents a fantastic opportunity for improvement. Ideally, the notification of
revision changes and concurrent engineering changes should be completely automated
and the planner notified of the individual changes where this overlap might occur. This
results in a proactive resolution identifying which changes would take priority, as
opposed to a reactive response to a fully printed package.
Another improvement available with current technology is the ability to electronically
Planners and field distribute the change package to the field. In this case, a well-designed electronic
workers are then free to design change software tool will have the ability to push the approved package,
print, view, or otherwise including all engineering products, completed forms, and related information assets,
use and collaborate on to an entrenched collaboration tool such as SharePoint. Planners and field workers
the change package are then free to print, view, or otherwise use and collaborate on the change package
documents. In the absence of such a tool, any electronic kiosk serves the same
documents.
purpose, such as a web portal or customized web application designed to allow
plant workers easy access to controlled information like drawings and procedures.
Additionally, with an electronic design change process, the information is integrated and
visible to other business processes throughout the plant. The project management aspects
of the implementation would allow field workers to seamlessly navigate the project
schedule, collaborate on ongoing or future work, and add value to the implementation
process without needing to understand a plethora of different applications.

Change Package Closeout
The change package closeout is often the most challenging of the design change
processes. Change notices (documents that reflect the modifications’ ‘as planned’
configuration versus the current ‘as-built’ configuration) are a necessity of the
modification process. Until the modification is implemented it does not represent
the true configuration of the plant. Correct operation of the plant requires accurate
identification of the plant configuration. However, the failure to update these change
notices in a timely fashion after implementation can lead to regulatory findings.


Many plants can attest to having received regulatory findings ranging from ‘lack of rigor
in the design change process’ and ‘inadequate drawing management disciplines,’ to
‘exceeding the recommended change notice count on calculations,’ among other findings.
These problems stem from multiple sources, but the cost and effort involved in the
closeout process are the most significant. Most documents, especially drawings, have
very specific requirements in terms of their turnaround time from field implementation
to release. For example, drawings with a class of ‘essential,’ ‘class 1’ or ‘A class’ have a
mandatory 24-hour turnaround time due to their importance to operations. These documents
are most often handled according to guidelines and don’t get plants in trouble.
The remaining documents in the closeout process have less restrictive closeout
The remaining documents routines and are prioritized primarily based on cost and resource availability factors.
in the closeout process This is where problems typically arise. The configuration department makes judgment
have less restrictive calls based on whether the incorporation of redlines or change notices into the source
closeout routines and are drawings are worth prioritizing based on the potentially significant expense and
prioritized primarily based dedication of staff. In many cases, they leave the change notices attached as a
on cost and resource separate annotation rather than incorporate them into the source document.
availability factors. Unfortunately, a drawing with too many attached change notices is prone to cause
errors. This happens because when change notices are not identified, it is difficult to
determine what the as-built configuration is when change notices conflict with each
other, or if they are of poor quality, or no longer valid. In this scenario, the user’s
interpretation of the information becomes extremely challenging, and there is a high
risk of making decisions based on incorrect or incomplete information.
In response, regulatory agencies enforce an arbitrary cap, such as limiting the allowed
number of change notices per document to five. However, a more effective and efficient
solution is to implement an electronic design change process based on industry best practices.
An electronic design change process with robust software support will provide a
method of minimizing the risk by maintaining a controlled process where anyone
can find the applicable design basis information. Most significantly, a proper change
request and change notice infrastructure would allow for an easier and less resource
intensive closeout process. An electronic infrastructure allows the establishment of
permanent relationships between change notices and the source documents. This
way, the outstanding change notices are visible and reportable, ensuring drawing and
document accuracy and integrity.

Quality Records and Records Management for Change Packages
All nuclear facilities are required to review, approve, and store engineering products
(as well as their revisions) in an approved records management system. The system
must comply with the NRC’s RIS-2000 regulatory requirements for dual storage, record
continuity, and format changes. An electronic design change process must comply with
these requirements, linking both the change and the requirement within the system.
This frees the user from having to search for the specs in order to ensure compliance.


Ideally, the design change process solution will be able to leverage the information
already present in the records management system. In this way, documents created
outside the regular engineering process, like training records, qualifications, procedure
updates, etc., can also be considered during the modification process as part of the
previously mentioned effects analysis.

Bentley’s eB Electronic Design Change Process
Bentley’s eB Design Engineering application encapsulates the full complement of tools
needed by design engineers to perform comprehensive electronic design changes.
Moreover, this process is designed to fully blend with eB performance improvement,
document control, and records management, as well as asset management modules.
This combination provides a powerful platform for engineers to initiate, process,
implement, and close out engineering change packages.
The design change management capability in eB was developed in conjunction with
design engineers who experienced the very issues identified in this white paper. As
such, the solutions provided by this application specifically and precisely address these
problem areas. Obviously, plants are all somewhat unique in their approach to design
change, but ultimately the problem set and the regulatory requirements are the same
for everyone. eB configurable workflow allows plant operators to use this robust tool
to match their existing nonelectronic processes, and its ability to create relationship
links among information assets in disparate information systems ensures thorough and
accurate change effects analysis.
Through expansive consulting and collaboration with some of the largest utilities in the
country, Bentley’s eB Design Engineering application has been developed as a truly
industry-wide resolution to a complex problem.

The Complete eB Nuclear Application Suite
TE
SUI
TRAINING
N COMPLIANCE
L
Licensing, Requirements
APPLICATIO

DESIGN ENGINEERING
Design Engineering Management
Cable/Raceway Management

INFORMATION MANAGEMENT
Controlled Documents, Records Management

PERFORMANCE IMPROVEMENT
R

Corrective Action, Human Performance,
EA Operating Experience
NUCL KNOWLEDGE MANAGEMENT

The applications in the eB Nuclear Application Suite are designed based on industry best practices and
guidelines from industry regulatory and advisory agencies.


Bentley’s eB Design Change Process: A Summary
The elements of any design change are made up of the following elements: problem
identification, scope determination, package creation, and review and approval. Below
is a graphic depiction of a typical design change package.

eB Design Change Process
A. Problem Identification
Electronic Approval
Action /
Service eB
Request Work
Order

B. Change Request D. Change Disposition

Change Modification
Request Package

C. Affected Information Assets E. Engineering Products

Prototype created from Affected Item

AS PLANNED
AS BUILT

Affected Prototype
Item Item

Mark Up created from Affected Document

Affected Mark Up
Document Document

F. WORKFLOW

A) Problem Identification: In this case we show a request for resolution (also known as engineering request for
information – RFI). eB can either use its own internal corrective action and action tracking capability, or interface
with an external system.
B) Change Request: The change request is used to describe the nature of the problem, its priority, and any additional
user-defined information applicable to this phase of the project.
C) Affected Information Assets: These are the documents and components that are directly affected by the proposed
change. They are related to the change request and will eventually describe the full scope of the change.
D) Change Disposition (also known as modification package): The change disposition encapsulates all the
engineering products that will be issued to the field. The change disposition can also be configured to have additional
user-defined attributes, including the engineering impact, whether it is a safety-related package, etc.
E) Engineering Products: These are related or encapsulated by the change disposition and may be independently
tracked through eB in terms of review and approval. Some plant operators prefer to only review the package as a
complete entity and approving the package implies that all the engineering products were also reviewed.
F) The Workflow Element: The eB workflow capability is used to track the entire package through creation, review,
approval, implementation, and closeout.


What to make of it all
As most design engineers can attest, the design change process can be simple or
very complex, depending on the nature and scope of the change. Moreover, complex
engineering elements such as cable and raceway changes, calculations, set-points,
and equivalencies can complicate the process even further.
Bentley’s eB Design Engineering design change application was created based on
input and best practices of facilities that face these challenges every day.
In these trying economic times, organizations seek technologies that lower cost
Bentley’s eB vastly of operations, increase operational efficiency, and reduce the risk of regulatory
improves the integrity, noncompliance to gain competitive advantage. Bentley’s eB vastly improves the
visibility, and access to all integrity, visibility, and access to all relevant information at the time it is needed.
relevant information at the Bentley Systems would like to thank the following contributors and reviewers:
time it is needed.
Scott Clardy, supervisor, configuration management,
AmerenUE - Callaway Nuclear Plant
Janice Hoerber, IT supervisor, development operations,
Nick Olivia, general supervisor engineering,
Constellation Energy Nuclear Group
Laurent Perkins, senior solutions architect,
Enterprise Informatics
Ben Scott, supervisor, configuration management,
CENG Fleet Engineering, Constellation Energy Nuclear Group
Tom Stotlar, supervising engineer, configuration control,


About AssetWise
Bentley’s AssetWise platform combines multiple information modeling services to
improve the lifecycle management and operational performance, safety, compliance,
and governance of infrastructure assets while increasing the return on investment
for owner-operators. AssetWise enables operations and maintenance to take full
advantage of information modeling and thus realize the potential of intelligent
infrastructure assets. The AssetWise platform encompasses eB Insight, featuring
powerful asset lifecycle information management capabilities to manage change and
to control information throughout the lifecycle of infrastructure, and Exor, providing
for the management and operations of linear networks including roads, rails, and
utilities. AssetWise applications include SUPERLOAD, facilitating intelligent permitting
and routing of oversize-overweight vehicles, and Optram, a decision support system
enabling proactive management of railway assets. For additional information about
Bentley’s AssetWise offerings, visit www.bentley.com/AssetWise.

About Bentley Systems, Incorporated
Bentley is the global leader dedicated to providing architects, engineers, geospatial
professionals, constructors, and owner-operators with comprehensive software
solutions for sustaining infrastructure. Bentley’s mission is to empower its users
to leverage information modeling through integrated projects for high-performing
intelligent infrastructure. Its solutions encompass the MicroStation platform for
infrastructure design and modeling, the ProjectWise platform for infrastructure project
team collaboration and work sharing, and the AssetWise platform for infrastructure
asset operations – all supporting a broad portfolio of interoperable applications and
complemented by worldwide professional services. Founded in 1984, Bentley has
grown to nearly 3,000 colleagues in more than 45 countries and $500 million in annual
revenues. Since 2001, the company has invested more than $1 billion in research,
development, and acquisitions.

© 2011 Bentley Systems, Incorporated. Bentley, the “B” Bentley logo, eB, and eB Superload are either registered or unregistered trademarks or
service marks of Bentley Systems, Incorporated or one of its direct or indirect wholly owned subsidiaries. Other brands and product names are trademarks of
their respective owners.


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