[Federal Register Volume 81, Number 156 (Friday, August 12, 2016)]
[Notices]
[Pages 53428-53431]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-19373]


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DEPARTMENT OF COMMERCE

International Trade Administration

[A-489-826]


Certain Hot-Rolled Steel Flat Products From the Republic of 
Turkey: Final Determination of Sales at Less Than Fair Value

AGENCY: Enforcement and Compliance, International Trade Administration, 
Department of Commerce.

SUMMARY: The Department of Commerce (the Department) determines that 
imports of certain hot-rolled steel flat products (hot-rolled steel) 
from the Republic of Turkey (Turkey) are being, or are likely to be, 
sold in the United States at less than fair value (LTFV). The period of 
investigation (POI) is July 1, 2014, through June 30, 2015. The final 
dumping margins of sales at LTFV are listed below in the ``Final 
Determination'' section of this notice.

DATES: Effective August 12, 2016.

FOR FURTHER INFORMATION CONTACT: Toni Page or Alexander Cipolla, AD/CVD 
Operations, Office VII, Enforcement and Compliance, International Trade 
Administration, U.S. Department of Commerce, 14th Street and 
Constitution Avenue NW., Washington, DC 20230; telephone: (202) 482-
1398 or (202) 482-4956, respectively.

SUPPLEMENTARY INFORMATION:

Background

    On March 22, 2016, the Department published the Preliminary 
Determination of this antidumping duty (AD) investigation.\1\ The 
following events occurred since the Preliminary Determination was 
issued.
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    \1\ See Certain Hot-Rolled Steel Flat Products From the Republic 
of Turkey: Affirmative Preliminary Determination of Sales at Less 
Than Fair Value and Postponement of Final Determination, 81 FR 15231 
(March 22, 2016) (Preliminary Determination) and accompanying 
Preliminary Decision Memorandum.
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    The Department received case and rebuttal briefs from Petitioners, 
Erdemir, and Colakoglu between June 7 and June 20, 2016.\2\ A hearing 
was held on June 23, 2016.\3\
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    \2\ See the ``Table of Authorities'' in the Final Issues and 
Decision Memorandum for a complete list of case and rebuttal briefs 
filed.
    \3\ See ``Transcript of Hearing in the Antidumping Duty 
Investigation of Certain Hot-Rolled Steel Flat Products from the 
Republic of Turkey'' (June 30, 2016).
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Scope of the Investigation

    The products covered by this investigation are hot-rolled steel 
flat products from Turkey. For a full description of the scope of this 
investigation, see the ``Scope of the Investigation,'' in Appendix I of 
this notice.

Scope Comments

    In the Preliminary Scope Decision Memorandum,\4\ the Department set 
aside a period of time for parties to address scope issues in case 
briefs or other written comments on scope issues.
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    \4\ See Memorandum to Christian Marsh, Deputy Assistant 
Secretary for Antidumping and Countervailing Duty Operations, 
``Certain Hot-Rolled Steel Products From Australia, Brazil, Japan, 
the Netherlands, the Republic of Korea, Turkey, and the United 
Kingdom: Scope Comments Decision Memorandum for the Preliminary 
Determinations,'' dated March 14, 2016 (Preliminary Scope Decision 
Memorandum).
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    In the Preliminary Determination, we did not modify the scope 
language as it appeared in the Initiation Notice.\5\ No interested 
parties submitted scope comments in case or rebuttal briefs; therefore, 
the scope of this investigation remains unchanged for this final 
determination.
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    \5\ See Preliminary Determination and accompanying Memorandum 
from Christian Marsh, Deputy Assistant Secretary for Antidumping and 
Countervailing Duty Operations, to Paul Piquado, Assistant Secretary 
for Enforcement and Compliance, entitled ``Decision Memorandum for 
the Preliminary Determination in the Less-Than-Fair-Value 
Investigation of Certain Hot-Rolled Steel Flat Products from the 
Republic of Turkey'' at page 5. See also Certain Hot-Rolled Steel 
Flat Products From Australia, Brazil, Japan, the Republic of Korea, 
the Netherlands, The Republic of Turkey, and the United Kingdom: 
Initiation of Less-Than-Fair-Value Investigations, 80 FR 54261, 
54262 (September 9, 2015) (Initiation Notice).
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Analysis of Comments Received

    All issues raised in the case and rebuttal briefs by parties in 
this investigation are addressed in the Final Issues and Decision 
Memorandum, which is hereby adopted by this notice.\6\ A list of the 
issues raised is attached to this notice as Appendix II. The Final 
Issues and Decision Memorandum is a public document and is on file 
electronically via Enforcement and Compliance's Antidumping and 
Countervailing Duty Centralized Electronic Service System (ACCESS). 
ACCESS is available to registered users at https://access.trade.gov and 
it is available to all parties in the Central Records Unit, Room B-8024 
of the main Department of Commerce building. In addition, a complete 
version of the Final Issues and Decision Memorandum can be accessed 
directly at http://enforcement.trade.gov/frn/index.html. The signed and 
electronic versions of the Final Issues and Decision Memorandum are 
identical in content.
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    \6\ See Memorandum to Ronald K. Lorentzen, Acting Assistant 
Secretary for Enforcement and Compliance, entitled ``Issues and 
Decision Memorandum for the Final Determination in the Antidumping 
Duty Investigation of Certain Hot-Rolled Steel Flat Products from 
the Republic of Turkey,'' dated August 4, 2016 (Final Issues and 
Decision Memorandum).
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Verification

    As provided in section 782(i) of the Tariff Act of 1930, as amended 
(the Act), in March, April, and May 2016, the Department verified the 
sales and cost data reported by the mandatory respondents Colakoglu 
Metalurji A.S. (Colakoglu), Colakoglu Dis Ticaret A.S. (COTAS), and 
Medtrade Incorporated (Medtrade) (collectively, Colakoglu) and Eregli 
Demir ve Celik Fabrikalari T.A.S. (Erdemir) and Iskenderun Demir Ve 
Celik (Iskenderun) (collectively, Erdemir). We used standard 
verification procedures, including an examination of

[[Page 53429]]

relevant accounting and production records, and original source 
documents provided by respondents.\7\
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    \7\ See Memorandum to the File, ``Verification of the Sales 
Response of Colakoglu Metalurji A.S. (Metalurji), Colakoglu Dis 
Ticaret A.S. (COTAS), and Medtrade Incorporated (Medtrade) in the 
Antidumping Duty Investigation of Hot-Rolled Steel Flat Products 
from the Republic of Turkey,'' (June 1, 2016) (Colakoglu Sales 
Verification Report); see also Memoradum to the File, ``Verification 
of the U.S. Sales Responses of Colakoglu Metalurji A.S. (Metalurji), 
Colakoglu Dis Ticaret A.S. (COTAS),and Medtrade Incorporated 
(Medtrade) in the Antidumping Duty Investigation of Hot-Rolled Steel 
Flat Products from the Republic of Turkey,'' (June 1, 2016) 
(Colakoglu CEP Sales Verification Report); see also Memoradum to the 
File, ``Verification of the Cost Response of Colakoglu Metalurji 
A.S. and its Affiliates in the Antidumping Duty Investigation of 
Hot-Rolled Steel Flat Product from Turkey,'' (June 1, 2016) 
(Colakoglu Cost Verification Report); see also Memorandum to the 
File, ``Verification of the Sales Response of Ere[gbreve]li Demir ve 
[Ccedil]elik Fabrikalar[inodot] T.A.[Scedil]. in the Antidumping 
Investigation of Hot Rolled Steel Flat Products from Turkey,'' (May 
31, 2016) (Erdemir Sales Verification Report); see also Memorandum 
to the File, ``Verification of the Cost Response of Eregli Demir ve 
Celik Fabrikalari T.A.S. and its affiliates Iskenderun Demir Ve 
Celik,'' (May 30, 2016) (Erdemir Cost Verification Report).
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Changes Since the Preliminary Determination

    Based on our analysis of the comments received and our findings at 
verification, we made certain changes to the margin calculations for 
Colakoglu and Erdemir. For a discussion of these changes, see the Final 
Issues and Decision Memorandum. We have also revised the all-others 
rate.

All-Others Rate

    Section 735(c)(5)(A) of the Act provides that the estimated all-
others rate shall be an amount equal to the weighted-average of the 
estimated weighted-average dumping margins established for exporters 
and producers individually investigated excluding any zero or de 
minimis margins, and margins determined entirely under section 776 of 
the Act. Where the rates for investigated companies are zero or de 
minimis, or based entirely on facts otherwise available, section 
735(c)(5)(B) of the Act instructs the Department to establish an ``all 
others'' rate using ``any reasonable method.''
    In this investigation, we calculated weighted-average dumping 
margins for Colakoglu and Erdemir, that are above de minimis and which 
are not based entirely on facts available. We calculated the all-others 
rate using a weighted-average of the dumping margins calculated for the 
mandatory respondents using each company's publicly-ranged values for 
the merchandise under consideration.\8\
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    \8\ With two respondents, we normally calculate (A) a weighted-
average of the dumping margins calculated for the mandatory 
respondents; (B) a simple average of the dumping margins calculated 
for the mandatory respondents; and (C) a weighted-average of the 
dumping margins calculated for the mandatory respondents using each 
company's publicly-ranged values for the merchandise under 
consideration. We would compare (B) and (C) to (A) and select the 
rate closest to (A) as the most appropriate rate for all other 
companies. See Ball Bearings and Parts Thereof From France, Germany, 
Italy, Japan, and the United Kingdom: Final Results of Antidumping 
Duty Administrative Reviews, Final Results of Changed-Circumstances 
Review, and Revocation of an Order in Part, 75 FR 53661, 53663 
(September 1, 2010). As complete publicly ranged sales data was 
available, we based the all-others rate on the publically ranged 
sales data of the mandatory respondents. For a complete BPI 
explanation, please see Memorandum to the File, entitled 
``Antidumping Duty Investigation of Hot-Rolled Steel Flat Products 
from the Republic of Turkey: Final Determination Calculation for the 
`All-Others' Rate,'' dated August 4, 2016 (All-Others Calculation 
Memorandum).
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Final Determination

    The Department determines that the final weighted-average dumping 
margins are as follows:

------------------------------------------------------------------------
                                             Weighted-     Cash deposit
            Exporter/producer             average margin       rate
                                             (percent)       (percent)
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Colakoglu Metalurji A.S./Colakoglu Dis              7.15            7.15
 Ticaret A.S.\9\........................
Eregli Demir ve Celik Fabrikalari T.A.S./           3.66            3.65
 Iskenderun Demir Ve Celik \10\.........
All-Others..............................            6.67            6.67
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Disclosure

    We intend to disclose the calculations performed to interested 
parties within five days of the public announcement of this final 
determination in accordance with 19 CFR 351.224(b).
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    \9\ As in the Preliminary Determination, the Department 
continues to find that Colakoglu Metalurji A.S. and Colakoglu Dis 
Ticaret A.S. are a single entity. See ``the ``Affiliation and 
Collapsing'' section of the Preliminary Decision Memorandum.
    \10\ As in the Preliminary Determination, the Department 
continues to find that Eregli Demir ve Celik Fabrikalari T.A.S. and 
Iskenderun Demir Ve Celik are a single entity. See the ``Affiliation 
and Collapsing'' section of the Preliminary Decision Memorandum.
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Continuation of Suspension of Liquidation

    Pursuant to section 735(c)(1)(B) of the Act, the Department will 
instruct U.S. Customs and Border Protection (CBP) to continue to 
suspend liquidation of all entries of hot-rolled steel from Turkey, as 
described in Appendix I of this notice, which were entered, or 
withdrawn from warehouse, for consumption on or after March 22, 2016, 
the date of publication of the Preliminary Determination of this 
investigation in the Federal Register. We also will instruct CBP to 
require a cash deposit equal to the weighted-average amount by which 
normal value exceeds U.S. price, as indicated in the table above, 
adjusted, where appropriate, for export subsidies.
    As noted above, where the product under investigation is also 
subject to a concurrent countervailing duty investigation, we instruct 
CBP to require a cash deposit less the amount of the countervailing 
duty determined to constitute any export subsidies. Therefore, in the 
event that a countervailing duty order is issued and suspension of 
liquidation is resumed in the companion countervailing duty 
investigation on hot-rolled steel from Turkey, the Department will 
instruct CBP to require cash deposits adjusted by the amount of export 
subsidies, as appropriate.\11\ These adjustments are reflected in the 
``Cash Deposit Rate'' column of the rate chart, above. Until such 
suspension of liquidation is resumed in the companion countervailing 
duty investigation, and so long as suspension of liquidation continues 
under this antidumping duty investigation, the cash deposit rates for 
this antidumping duty investigation will be the rates identified in the 
weighted-average margin column in the rate chart, above.
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    \11\ See Memorandum to Thomas Gilgunn, Program Manager for AD/
CVD Operations Office VII, entitled ``Investigation of Certain Hot-
Rolled Steel Flat Products from the Republic of Turkey: Final 
Analysis Memorandum for Ere[gbreve]li Demir ve [Ccedil]elik 
Fabrikalari T.A.[Scedil]. and its Affiliates,'' dated August 4, 
2016. (Erdemir Final Calculation Memorandum) in the ``Adjustments to 
the Margin Program'' section.

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[[Page 53430]]

U.S. International Trade Commission Notification

    In accordance with section 735(d) of the Act, we will notify the 
U.S. International Trade Commission (ITC) of the final affirmative 
determination of sales at LTFV. Because the final determination in this 
proceeding is affirmative, in accordance with section 735(b)(2) of the 
Act, the ITC will make its final determination as to whether the 
domestic industry in the United States is materially injured, or 
threatened with material injury, by reason of imports of hot-rolled 
steel from Turkey no later than 45 days after our final determination. 
If the ITC determines that material injury or threat of material injury 
does not exist, the proceeding will be terminated and all cash deposits 
will be refunded. If the ITC determines that such injury does exist, 
the Department will issue an antidumping duty order directing CBP to 
assess, upon further instruction by the Department, antidumping duties 
on all imports of the subject merchandise entered, or withdrawn from 
warehouse, for consumption on or after the effective date of the 
suspension of liquidation as discussed in the ``Continuation of 
Suspension of Liquidation'' section.

Notification Regarding Administrative Protective Orders

    This notice serves as a reminder to parties subject to an 
administrative protective order (APO) of their responsibility 
concerning the disposition of proprietary information disclosed under 
APO in accordance with 19 CFR 351.305(a)(3). Timely notification of the 
return or destruction of APO materials, or conversion to judicial 
protective order, is hereby requested. Failure to comply with the 
regulations and the terms of an APO is a violation subject to sanction.
    This determination and this notice are issued and published 
pursuant to sections 735(d) and 777(i)(1) of the Act.

     Dated: August 4, 2016.
Ronald K. Lorentzen,
Acting Assistant Secretary for Enforcement and Compliance.

Appendix I

Scope of the Investigation

    The products covered by this investigation are certain hot-
rolled, flat-rolled steel products, with or without patterns in 
relief, and whether or not annealed, painted, varnished, or coated 
with plastics or other non-metallic substances. The products covered 
do not include those that are clad, plated, or coated with metal. 
The products covered include coils that have a width or other 
lateral measurement (``width'') of 12.7 mm or greater, regardless of 
thickness, and regardless of form of coil (e.g., in successively 
superimposed layers, spirally oscillating, etc.). The products 
covered also include products not in coils (e.g., in straight 
lengths) of a thickness of less than 4.75 mm and a width that is 
12.7 mm or greater and that measures at least 10 times the 
thickness. The products described above may be rectangular, square, 
circular, or other shape and include products of either rectangular 
or non-rectangular cross-section where such cross-section is achieve 
subsequent to the rolling process, i.e., products which have been 
``worked after rolling'' (e.g., products which have been beveled or 
rounded at the edges). For purposes of the width and thickness 
requirements referenced above:
    (1) Where the nominal and actual measurements vary, a product is 
within the scope if application of either the nominal or actual 
measurement would place it within the scope based on the definitions 
set forth above unless the resulting measurement makes the product 
covered by the existing antidumping \12\ or countervailing duty \13\ 
orders on Certain Cut-To-Length Carbon-Quality Steel Plate Products 
From the Republic of Korea (A-580-836; C-580-837), and
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    \12\ See Notice of Amendment of Final Determinations of Sales at 
Less Than Fair Value and Antidumping Duty Orders: Certain Cut-To-
Length Carbon-Quality Steel Plate Products From France, India, 
Indonesia, Italy, Japan and the Republic of Korea, 65 FR 6585 
(February 10, 2000).
    \13\ See Notice of Amended Final Determinations: Certain Cut-to-
Length Carbon-Quality Steel Plate From India and the Republic of 
Korea; and Notice of Countervailing Duty Orders: Certain Cut-To-
Length Carbon-Quality Steel Plate From France, India, Indonesia, 
Italy, and the Republic of Korea, 65 FR 6587 (February 10, 2000).
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    (2) where the width and thickness vary for a specific product 
(e.g., the thickness of certain products with non-rectangular cross-
section, the width of certain products with non-rectangular shape, 
etc.), the measurement at its greatest width or thickness applies.
    Steel products included in the scope of this investigation are 
products in which: (1) Iron predominates, by weight, over each of 
the other contained elements; (2) the carbon content is 2 percent or 
less, by weight; and (3) none of the elements listed below exceeds 
the quantity, by weight, respectively indicated:
     2.50 percent of manganese, or
     3.30 percent of silicon, or
     1.50 percent of copper, or
     1.50 percent of aluminum, or
     1.25 percent of chromium, or
     0.30 percent of cobalt, or
     0.40 percent of lead, or
     2.00 percent of nickel, or
     0.30 percent of tungsten, or
     0.80 percent of molybdenum, or
     0.10 percent of niobium, or
     0.30 percent of vanadium, or
     0.30 percent of zirconium.
    Unless specifically excluded, products are included in this 
scope regardless of levels of boron and titanium.
    For example, specifically included in this scope are vacuum 
degassed, fully stabilized (commonly referred to as interstitial-
free (IF)) steels, high strength low alloy (HSLA) steels, the 
substrate for motor lamination steels, Advanced High Strength Steels 
(AHSS), and Ultra High Strength Steels (UHSS). IF steels are 
recognized as low carbon steels with micro-alloying levels of 
elements such as titanium and/or niobium added to stabilize carbon 
and nitrogen elements. HSLA steels are recognized as steels with 
micro-alloying levels of elements such as chromium, copper, niobium, 
titanium, vanadium, and molybdenum. The substrate for motor 
lamination steels contains micro-alloying levels of elements such as 
silicon and aluminum. AHSS and UHSS are considered high tensile 
strength and high elongation steels, although AHSS and UHSS are 
covered whether or not they are high tensile strength or high 
elongation steels.
    Subject merchandise includes hot-rolled steel that has been 
further processed in a third country, including but not limited to 
pickling, oiling, levelling, annealing, tempering, temper rolling, 
skin passing, painting, varnishing, trimming, cutting, punching, 
and/or slitting, or any other processing that would not otherwise 
remove the merchandise from the scope of the investigation if 
performed in the country of manufacture of the hot-rolled steel.
    All products that meet the written physical description, and in 
which the chemistry quantities do not exceed any one of the noted 
element levels listed above, are within the scope of this 
investigation unless specifically excluded. The following products 
are outside of and/or specifically excluded from the scope of this 
investigation:
     Universal mill plates (i.e., hot-rolled, flat-rolled 
products not in coils that have been rolled on four faces or in a 
closed box pass, of a width exceeding 150 mm but not exceeding 1250 
mm, of a thickness not less than 4.0 mm, and without patterns in 
relief);
     Products that have been cold-rolled (cold-reduced) 
after hot-rolling; \14\
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    \14\ For purposes of this scope exclusion, rolling operations 
such as a skin pass, levelling, temper rolling or other minor 
rolling operations after the hot-rolling process for purposes of 
surface finish, flatness, shape control, or gauge control do not 
constitute cold-rolling sufficient to meet this exclusion.
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     Ball bearing steels; \15\
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    \15\ Ball bearing steels are defined as steels which contain, in 
addition to iron, each of the following elements by weight in the 
amount specified: (i) Not less than 0.95 nor more than 1.13 percent 
of carbon; (ii) not less than 0.22 nor more than 0.48 percent of 
manganese; (iii) none, or not more than 0.03 percent of sulfur; (iv) 
none, or not more than 0.03 percent of phosphorus; (v) not less than 
0.18 nor more than 0.37 percent of silicon; (vi) not less than 1.25 
nor more than 1.65 percent of chromium; (vii) none, or not more than 
0.28 percent of nickel; (viii) none, or not more than 0.38 percent 
of copper; and (ix) none, or not more than 0.09 percent of 
molybdenum.
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     Tool steels; \16\ and
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    \16\ Tool steels are defined as steels which contain the 
following combinations of elements in the quantity by weight 
respectively indicated: (i) More than 1.2 percent carbon and more 
than 10.5 percent chromium; or (ii) not less than 0.3 percent carbon 
and 1.25 percent or more but less than 10.5 percent chromium; or 
(iii) not less than 0.85 percent carbon and 1 percent to 1.8 
percent, inclusive, manganese; or (iv) 0.9 percent to 1.2 percent, 
inclusive, chromium and 0.9 percent to 1.4 percent, inclusive, 
molybdenum; or (v) not less than 0.5 percent carbon and not less 
than 3.5 percent molybdenum; or (vi) not less than 0.5 percent 
carbon and not less than 5.5 percent tungsten.

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[[Page 53431]]

     Silico-manganese steels; \17\
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    \17\ Silico-manganese steel is defined as steels containing by 
weight: (i) Not more than 0.7 percent of carbon; (ii) 0.5 percent or 
more but not more than 1.9 percent of manganese, and (iii) 0.6 
percent or more but not more than 2.3 percent of silicon.
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    The products subject to this investigation are currently 
classified in the Harmonized Tariff Schedule of the United States 
(HTSUS) under item numbers: 7208.10.1500, 7208.10.3000, 
7208.10.6000, 7208.25.3000, 7208.25.6000, 7208.26.0030, 
7208.26.0060, 7208.27.0030, 7208.27.0060, 7208.36.0030, 
7208.36.0060, 7208.37.0030, 7208.37.0060, 7208.38.0015, 
7208.38.0030, 7208.38.0090, 7208.39.0015, 7208.39.0030, 
7208.39.0090, 7208.40.6030, 7208.40.6060, 7208.53.0000, 
7208.54.0000, 7208.90.0000, 7210.70.3000, 7211.14.0030, 
7211.14.0090, 7211.19.1500, 7211.19.2000, 7211.19.3000, 
7211.19.4500, 7211.19.6000, 7211.19.7530, 7211.19.7560, 
7211.19.7590, 7225.11.0000, 7225.19.0000, 7225.30.3050, 
7225.30.7000, 7225.40.7000, 7225.99.0090, 7226.11.1000, 
7226.11.9030, 7226.11.9060, 7226.19.1000, 7226.19.9000, 
7226.91.5000, 7226.91.7000, and 7226.91.8000. The products subject 
to the investigation may also enter under the following HTSUS 
numbers: 7210.90.9000, 7211.90.0000, 7212.40.1000, 7212.40.5000, 
7212.50.0000, 7214.91.0015, 7214.91.0060, 7214.91.0090, 
7214.99.0060, 7214.99.0075, 7214.99.0090, 7215.90.5000, 
7226.99.0180, and 7228.60.6000.
    The HTSUS subheadings above are provided for convenience and 
U.S. Customs and Border Protection purposes only. The written 
description of the scope of the investigation is dispositive.

Appendix II

List of Topics Discussed in the Final Issues and Decision Memorandum

I. Summary
II. Background
III. Scope of the Investigation
IV. Scope Comments
V. Changes Since the Preliminary Determination
VI. Margin Calculations
VII. Discussion of the Issues
    Comment 1: Colakoglu's Duty Drawback Adjustment
    Comment 2: Colakoglu's U.S. Indirect Selling Expenses
    Comment 3: Colakoglu's International Ocean Freight
    Comment 4: Colakoglu's U.S. Commissions
    Comment 5: Corrections to Colakoglu's Cost Database
    Comment 6: Colakoglu's Cost-Averaging Methodology
    Comment 7: Colakoglu's Electricity Offset
    Comment 8: Colakoglu's General and Administrative Expense Ratio
    Comment 9: Using Partial Facts Available for Erdemir's 
Downstream Reseller Ersem
    Comment 10: Erdemir's Date of Sale
    Comment 11: Erdemir's Unreconciled Cost
    Comment 12: Erdemir's Major-Input and Transactions-Disregarded 
Adjustments
    Comment 13: Erdemir's Financial Expenses
    Comment 14: Erdemir's Cost of Goods Sold Denominator
    Comment 15: Erdemir's General and Administrative Expenses
VIII. Recommendation

[FR Doc. 2016-19373 Filed 8-11-16; 8:45 am]
 BILLING CODE 3510-DS-P