Model  General  Permit:
Specific Conditions  And

Instructions  For Use
Perchloroethylene Dry Cleaners:
40 CFR Part 63, Subpart M (Proposed) and
Control Technique Guideline for Control of Volatile Organic Emissions from
Perchloroethylene  Dry Cleaning Systems, December  1978
Submitted To:

Jeffrey Herring
Work Assignment Manager
OAQPS/AQMD/PPB
By:

ViGYAN Inc.
May 18, 1993

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                                453R93O6O
    MODEL GENERAL PERMIT:
      SPECIFIC CONDITIONS

 PERCHLOROETHYLENE DRY CLEANERS
        40 CFR Part 63, Subpart M (Proposed)
                 and
Control Technique Guideline for "Control of Volatile Organic Emissions
  from Perchloroethylene Dry Cleaning Systems", December 1978
        EPA -RTF LIBRARY

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                       SECTION I: APPLICABILITY CRITERIA


A.     The  provisions  of this permit  apply  to  dry cleaning  dryers, dry-to-dry  machines,
       transfer machine systems, filters, muck cookers, and  stills at dry cleaning facilities
       that use perchloroethylene as a solvent.

       (1)     The permittee shall comply with Section fl of this permit for each  dry-to-dry
              machine, except

              (a)    For each existing dry-to-dry machine that consumes 830 liters per year
                    (220  gallons- per  year)  or less of  perchloroethylene  shall only  be
                    required to keep  and maintain for a period of 5 years records of the
                    amount of perchloroethylene  consumed per year.

       (2)     The permittee shall comply with Section m.l of this permit  for each existing
              transfer  machine  with a  potential  to emit of less than 10 tons per year and
              controlled by a refrigerated condenser, except

              (a)    For each existing transfer  machine system that consumes 1,100 liters
                    per year (300 gallons per year) or less of perchloroethylene  shall only
                    be required  to keep and maintain for a period of 5 years the records
                    of the amount  of perchloroethylene  consumed  per year.

       (3)     The permittee  shall comply with  Section ffl.2 of this permit for  each new,
              reconstructed, or  uncontrolled  transfer  machine,  and  existing refrigerated
              condenser-controlled  transfer machine with a potential to emit of 10 tons per
              year or  more.

B.     The  permittee  of a stationary source  affected by this subpart shall  comply with the
       provisions  of 40 CFR Part 63, Subpart A.
                                                                            Page 1 of 7

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   SECTION D: COMPLIANCE REQUIREMENTS FOR DRY-TO-DRY MACHINES
A.     OPERATING  REQUIREMENTS

       (1)    The permittee  shall vent  the  entire  exhaust  through  a  carbon  adsorber,
             refrigerated  condenser,  or  equally  effective control device or circulate  the
             entire  exhaust through  such a control device for a  ventless machine.   A
             permittee  using an equally effective  control device shall follow the procedures
             outlined  in II.A(ll) of this  permit.

             (a)    The  maximum organic solvent concentration  in the vent from the dryer
                    control  device shall  not exceed  [100] ppm  before  dilution

       (2)    If a carbon  adsorber  is  used to  achieve  compliance  with this section,  the
             permittee  shall operate  it to  meet the  following requirements.

             (a)    Desorption shall be performed periodically, and no less frequently than
                    each time the machine cleans 3 kilograms  of articles per kilogram of
                    activated carbon, based on dry-to-dry machine rated capacity;

             (b)    Desorption shall be  performed with a minimum steam pressure of 170
                    kilopascals;

             (c)    A rated air flow capacity at least equal to the unrestricted  exhaust rate
                    of the dry cleaning machine shall be achieved and a minimum  air flow
                    capacity shall be maintained  at 0.3 cubic meters per second; and

             (d)    No  bypass  to the atmosphere shall be permitted during desorption.

       (3)    If a refrigerated condenser  is used to achieve compliance  with this section, the
             permittee  shall vent no exhaust gases to the atmosphere  or circulate  exhaust
             gases through  a ventless  machine until the air-vapor  stream temperature   on
             the outlet side of the refrigerated  condenser  is less than or equal  to 4 4 °C (40
       (4)     For cartridge filters  subject to the provisions of this  permit,  the  permittee
              shall drain all  of used cartridge  filters  in  their  housing, or  other  sealed
              container,  for a minimum  of 24 hours, or have been  dried  in an  enclosure
              vented  to the control  device, prior to disposal of the used cartridge filter

       (5)     The  permittee  shall  store  all perchloroethylene   and wastes  that  contain
              perchloroethylene  in tightly sealed containers  which  are  impervious to the
              solvent and chemical  reaction  of the  perchloroethylene.
                                                                            Page 2 of 7

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       (6)     The permittee  shall minimize the time  that  the  door of the dry  cleaning
              machine remains  open.

       (7)     The   permittee   shall  clean   lint   traps   frequently   and   place   this
              perchloroethylene-laden   lint  in a  tightly  sealed  container  as described  in
              II.A(5) of this section.

       (8)     The permittee  shall allow  no liquid  leakage of  organic  solvent  from the
              system.

       (9)     The permittee shall ensure  that gaseous leakage does  not exceed [   ] ppm.

       (10)    The permittee shall meet the  following requirements  which apply to all filter
              and distillation  wastes:

              (a)    Residue  from any diatomaceous  earth filter  shall be cooked or treated
                    so that wastes shall not contain  more the [25] kg of solvent per 100  kg
                    of wet waste material.

              (b)    The residue  from a  solvent shall  not contain  more than  [60] kg  of
                    solvent per 100 kg of wet  waste material.

              (c)    The permittee  may  use an equivalent  filtration or distillation system
                    provided the  permittee  can demonstrate  that  the  equivalent system
                    reduces waste losses  below 1 kg solvent per 100 kg clothes cleaned

       (11)    Equivalent  equipment  and  procedures.

              (a)    [Insert appropriate  requirements  or conditions.]

              (b)    Equivalent equipment  or procedures must attain  95 percent control  of
                    perchloroethylene emissions.

B.     TESTING  AND  MONITORING

       (1)     The permittee  shall  make  at least   a weekly inspection  of  the  following
              components   for  leaks either visually  or using  a  portable  halogenated-
              hydrocarbon  detector:

              (a)    Hose connections, unions, couplings, and valves,

              (b)    Machine door gaskets  and searings;

              (c)    Filter  head gasket and seating;

              (d)    Pumps,
                                                                             Page  3 of 7

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       (e)     Solvent base tanks and solvent  and waste storage containers;

       (f)     Water separators;

       (g)     Filter sludge recovery;

       (h)     Distillation  units;

       (i)     Divertor valves;

       (j)     Saturated  lint from the lint basket;  and

       (k)     Cartridge  filters.

(2)    The permittee  shall inspect  the following components  at least  [	] for vapor
       leaks either  visually or using  [   ]:

       (a)     Deodorizing and  aeration valves on dryers;

       (b)     Air and exhaust ductwork;  and

       (c)     lint screens  and bags, fan blades, and condensers for clogging or caking
              with lint.

(3)    The permittee  shall determine the dryer exhaust concentration  by [   ]

(4)    The permittee  shall  determine  the  amount  of solvent in earth  filter  and
       distillation  wastes  by  utilizing the test method described  by the American
       National  Standards  Institute  in the paper,  "Standard  Method  of Test  for
       Dilution of Gasoline-Engine  Crankcase Oils "

(5)    The permittee  shall repair perceptible  vapor or liquid perchloroethylene leaks
       immediately after  detecting  such  a leak.   If repair  parts  are  necessary,  a
       purchase  order for those parts  shall be  initiated  within 3 working days of
       detecting  such a leak.  Such repair  parts shall be installed within a reasonable
       penod of time after receipt.
                                                                         Page 4 of 7

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C.     RECORDKEEPING  REQUIREMENTS

       (1)    The permittee  shall keep and maintain for a period  of 5 years records of the
             following'

             (a)    The amount  of perchloroethylene  consumed  per  year;

             (b)    The result of weekly inspections conducted under n.B(l), and records
                   of  the  dates  of repair  or  purchase   orders  for  repair   parts  to
                   demonstrate  compliance  with C.B(2) of this permit.  The  record or log
                   of weekly  inspections must be  posted in an area  that is  accessible  or
                   visible to workers in the plant  and  to enforcement officials; and

             (c)    The frequency and  period  of desorption  to show  compliance  with
                   H A(2)(a).

D.     REPORTING  REQUIREMENTS

       (1)    For the  purposes of this permit, if any of the  information  required by this
             permit is required to  be submitted  to another  Agency of State,  then the  dry
             cleaning permittee may submit  a copy of this information.
                                                                          Page  5 of 7

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   SECTION ffl:  COMPLIANCE REQUIREMENTS FOR TRANSFER MACHINES



             The  following provisions apply  only to existing  transfer  machines  with a
             potential  to emit of less than  10 tons per year and controlled by refrigerated
             condensers*

A.    OPERATING  REQUIREMENTS

      (1)   The permittee  shall meet the  requirements  of n.A(4)-(ll)  above.

      (2)   The permittee  shall vent the entire exhaust through a refrigerated  condenser
            or equally effective control device.

      (3)   Equivalent  equipment  and procedures.

            (a)    [Insert appropriate requirements  or conditions.]

            (b)    Equivalent equipment  or procedures  must attain 85 percent control of
                   perchloroethylene  emissions.

B.    TESTING AND  MONITORING

      (1)   The permittee  shall meet the  requirement  of n.B above

C     RECORDKEEPING   REQUIREMENTS

      (1)   The permittee  shall meet the  requirements  of II.C(l)(a)-(b) above

D.    REPORTING  REQUIREMENTS

      (1)   The permittee  shall meet the  requirements  of n D above.
                                                                       Page 6 of 7

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              The following provisions apply to new, reconstructed, or uncontrolled  transfer
              machines,  and existing refrigerated  condenser controlled transfer machines
              with a potential to emit of 10 tons per year or more:

A     OPERATING  REQUIREMENTS

      (1)    The  permittee   shall meet  the  requirements  of n.A(2)-(3) and  II.A(5)-(12)
             above.

      (2).    The  permittee   shall vent the entire exhaust through a carbon  adsorber  or
             equally effective control  device.

B.     TESTING  AND MONITORING

      (1)    The permittee  shall meet the requirement  of II.B above.

C     RECORDKEEPING   REQUIREMENTS

      (1)    The permittee  shall meet the requirements  of II.C above.

D.    REPORTING  REQUIREMENTS

      (1)    The permittee  shall meet the requirements  of II.D above.

      (2)    For  each  existing transfer  machine  using  a refrigerated  condenser  that
             consumes  7,600 liters per  year  (2,000 gallons  per  year)  or  greater  of
             perchloroethylene,  the permittee  shall submit to the Administrator  a report
             stating  that the  source is  in compliance  with the  provisions  of m.2(A)(2)
             above.  The statement  of compliance shall  be sent by registered letter on the
             30th day following compliance.
                                                                          Page 7 of 7

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PREFACE TO INSTRUCTIONS

The  general permit specific conditions  apply  to dry cleaning  dryers, dry-to-dry machines,
transfer machine  systems, filters, muck cookers, and  stills at dry cleaning facilities that use
perchloroethylene  as a solvent

Unless otherwise  identified in the  instructions,  all permit conditions  are based  on the
proposed  maximum  achievable control technology (MACT) regulation  40 CFR  Part 63.
"National  Emission  Standards  for Hazardous   Air Pollutants  for Source   Categories
Perchloroethylene  Emissions from Dry Cleaning  Facilities", published December 9, 1991

All conditions  identified as based on control technology guidance  (CTG) documentation are
from the CTG "Control of Volatile- Organic Emissions from Perchloroethylene Dry Cleaning
Systems",  published  December  1978.  These conditions  are based on  what EPA has
determined to be out-dated  information. EPA has proposed  to remove  perchloroethylene
from the list of volatile organic compounds (VOCs)  [FR Vol  57, pg 48490, October 26.
1992]  If this proposal  is adopted  (scheduled for Summer, 1993), the  CTG will be revoked,
and the terms  and conditions of this permit  that are based on the CTG will not be federally
enforceable.

The following sources are exempt from the requirements  of UA(1) or HI.2A(2), which are
based on CTG documentation:

       (1)    Each plant  where  an  adsorber   cannot  be  accommodated  because   of
             inadequate   space;

       (2)    Each plant  where no  or insufficient steam  capacity  is available  to desorb
             adsorbers;

       (3)    Each plant  that demonstrates  other  justifiable hardships.

The following sources are exempt from the provisions of 40  CFR Part 63, Subpart M, except
for the recordkeeping  requirements  of §63.325 (a)(l) and  (d)-

       (1)    Each existing dry-to-dry  machine  that consumes 830 liters  per year (220
             gallons per year) or  less of perchloroethylene,  and

       (2)    Each existing transfer machine system that consumes  1,100 liters per year (300
             gallons per year) or less of perchloroethylene.

The permittee of stationary  sources affected by this permit  shall comply  with the provisions
of 40 CFR 63 Subpart  A.
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As defined  in  §63.322(1), for purposes  of §63.9(b)(2)(vi),  a  major source is a dry-to-dry
machine  consuming  11,700 liters per year (3,100 gallons per year)  perchloroethylene  or
greater, or  a transfer machine  consuming 7,600 liters per year  (2,000 gallons per year)
perchloroethylene  or greater.  An area source is a dry-to-dry machine consuming less than
11,700 liters per year (3,100 gallons per year) perchloroethylene  or  a transfer machine
consuming less than 7,600 liters per  year (2,000 gallons per year) perchloroethylene.

Compliance schedule (from §63.322(e)):

       (1)    New  sources for which construction or reconstruction commences after [date
             of publication of Final rule] shall  achieve compliance upon  startup.

       (2)    Each existing dry-to-dry or transfer machine  with a design  capacity larger than
             22.7  kilograms  (50  pounds) shall achieve compliance  within 18 months of
             [date of publication of Final rule].

       (3)    Each existing dry-to-dry or transfer machine  with a design capacity that is 22.7
             kilograms (50 pounds)  or smaller  shall achieve compliance within 36 months
             of [date of  publication  of Final rule].

In delegating implementation  and enforcement  authority to a state  under Section  112(d) of
the Act, the authorities  contained  in §63.323 (Equivalent  equipment  and procedures)  shall
be retained  by the  Administrator  and not transferred  to a State.
INSTRUCTIONS

In the  sections that  follow, information  is presented  on regulatory requirements  under 40
CFR 63, Subpart M and the CTG identified  in the Preface to Instructions. Typically, these
sections explain the basis for each of the conditions  in the general permit specific conditions
document,  and provide  references  that  the  permitting   agency may use  for  additional
clarifications or details.  To  facilitate  using  these instructions,  each  section and  subsection
below  corresponds  to  the sections  and subsections  in the permit document

I.     This  section  identifies   the  applicability  catena   for  general   permits   for
       perchloroethylene  dry cleaners.

n.     This section covers provisions  that apply to all dry-to-dry machines

A.     OPERATING  REQUIREMENTS

       (1)     This  section covers methods  to vent  exhaust, as required  by §63.322(a).

              (a)    Specific organic  solvent concentration identified  in the CTG.


                                                                             Page 2 of 7

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(2)    Covers operation  requirements  required  by §63.322(c)  if a carbon adsorber
       is used to achieve compliance.

       (a)     Specific time requirement  for desorption performance,  as  required  by
              §63.222(c)(l).

       (b)     Specific pressure requirement  for desorption performance,  as required
              by §63.222(c)(2).

       (c)     Specific air flow capacity requirement,  as required  by §63 222(c)(3).

       (d)     Specific requirement  for control  during  desorption,  as required  by
              §63 222(c)(4).

(3)    This section  covers  venting requirements   for  machines  controlled  by a
       refrigerated  condenser.  For the purpose of measuring  the  temperature  of the
       perchloroethylene  vapors, a  thermometer  shall be installed on the outlet side
       of the refrigerated  condenser system for both vented  and  no-vent machines
       This section is based  on §63.322(d)

(4)    Specific condition  for cartridge  filters subject to the provisions of the  permit;
       required  by §63 222(0

(5)    Specific condition covering  the storage of all perchloroethylene  and  wastes
       that contain perchloroethylene.   This condition  is based on §63.222(i).

(6)    This condition, as required  by §63.222(j), minimizes the  time the  door of the
       dry cleaning machine remains  open.

(7)    Specific condition covering cleaning  of lint  traps, required by §63.322(k)

(8)    Specific liquid leakage  requirement identified  in the  CTG

(9)    Specific gaseous leakage  amount  limit identified in the  CTG.

(10)   Specific  requirements   identified  in  the  CTG for all filter and distillation
       wastes

       (a)     Specific requirement  for diatomaceous  earth filter residue.

       (b)     Specific requirement  for solvent residue  concentration  limit.

       (c)     Specific  requirement  for  allowable  use  of equivalent  filtration  or
              distillation  system.


                                                                       Page 3 of 7

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      (11)   The  regulations  allow an owner or operator to use approved equivalent  and
             procedures  to control  perchloroethylene   emissions.   This section  covers
             requirements,  as  identified  in  §63.323, necessary  for  use of  equivalent
             equipment   and  procedures  instead  of a  carbon  adsorber  or refrigerated
             condenser:

             The  permittee may submit a written application requesting  approval  from the
             Agency for the use of equipment or procedures that can be demonstrated  to
             be  equivalent  in terms  of reducing  perchloroethylene   emissions  to  the
             atmosphere  to those  prescribed for compliance within a specified  paragraph
             of this permit.  The  application shall contain the  following.

                    (i)     A complete description  of the testing procedure;

                    (ii)     The date, time, and location  of the test; and

                    (iii)    A description of the  results.

             Upon written application from any person, the Administrator may approve the
             use  of equipment  or procedures  that  have been  demonstrated   to  his
             satisfaction to be equivalent in terms of reducing perchloroethylene  emissions
             to the atmosphere,  to  those prescribed  for compliance  within a  specified
             paragraph of this  subpart.

             The  Administrator will make  a preliminary determination  of whether  the
             application  for equivalence  is approvable  and will publish  notice  of these
             findings  in  the Federal Register.  After notice  and  opportunity  for public
             hearing,  the Administrator will publish the final determination in the Federal
             Register.

             Authority to approve  equivalent equipment  and procedures is retained by the
             Administrator and not  delegated to the states.

             (a)    This provision was left blank  for any  appropriate  requirements  the
                    Agency or the Administrator  may wish to  insert  at  the appropriate
                    time.

             (b)    Specific emission control  requirement  for equivalent  equipment  and
                    procedures used in place  of carbon  adsorbers; based  on §63.323(b).

B.     TESTING  AND MONITORING

       (1)    This section identifies  all equipment  that must be  inspected at least weekly
             according to the provisions of §63.322(g) and  §63.324(a).


                                                                            Page 4 of 7

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       (2)    This section identifies all equipment that  must be inspected  for vapor leaks,
                    on CTG documentation.
       (3)     Specific determination of dryer exhaust concentration method identified in the
              CTG.

       (4)     Specific determination  of solvent  in  earth  filter and  -distillation  wastes
              identified in the  CTG.

       (5)     This section  covers repair  requirements for leaks; required  by §63.322(h).

C.     RECORDKEEPING   REQUIREMENTS

       (1)     Covers information  required  to be  maintained  by perchloroethylene  dry
              cleaning facilities.  All subsections  ((a)-(c)) apply  to dry cleaning machines
              controlled  by carbon  adsorbers  or equivalent;  only subsections  (a)  and (b)
              apply  to  dry cleaning machines controlled  by  refrigerated  condensers  or
              equivalent.  This section is required  by §63.325(a).

D.     REPORTING  REQUIREMENTS

       (1)     Specific condition as required  by §63.325(f).

       Initial  reporting  requirements:

       (§63.325(b))   Each  permittee  of a dry  cleaning facility subject to  the requirements
       of this permit shall  comply with the initial report requirements   in 40 CFR  Part 63,
       Subpart M, §63 9(b).

       (§63.325(c))  Each permittee  of a dry cleaning  facility subject to the requirements of
       this permit shall submit an initial statement of compliance to show that the provisions
       of §63.322(e)  are being  met.  The statement shall list the type of control device used
       to achieve initial compliance with §63.322 and other  appropriate  information as
       described  under the provisions of §63.9(h). The statement  of compliance  status shall
       be sent by registered  letter on the 30th day following the compliance  dates  given in
       §63.322(e)  in the  case of  existing sources,  or  simultaneously   with   the  initial
       notification  required  under  §63.325(b)  in the case of new or reconstructed  sources.

       (§63.325(d))  Each  permittee demonstrating  compliance with §63.320(b) or (c) shall
       perform the following:

              (a)     Submit to the  Administrator  an initial  report stating that  the  existing
                     source  is  consuming no more than 830 liters  per year (220 gallons per
                     year) of perchloroethylene  if it is a dry-to-dry  machine  and  no more


                                                                             Page 5 of 7

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                    than  1,100 liters  per year (300 gallons per year) of perchloroethylene
                    if it  is  a transfer  machine,  and  is, therefore,   exempt  from  the
                    requirements  of  §63.322(a) or §63 322(b).

             (b)    If during the  year the existing source  consumes more than 830 liters
                    per  year (200 gallons  per  year)  perchloroethylene   for  a  dry-to-dry
                    machine   or   1,100  liters   per  year   (300  gallons   per  year)
                    perchloroethylene  for a transfer  machine, then the source  permittee
                    shall  comply with the requirements  of §63.322(a) or §63.322(b) within
                    90 days. A compliance  report shall be submitted to the Administrator
                    within 90 days.

ffl.    This section  covers compliance requirements that apply to transfer  machines

              This  subsection   covers  provisions that apply  only to existing  transfer
              machines with a potential  to emit of less than 10 tons per  year and  controlled
              by refrigerated condensers.

A      OPERATING  REQUIREMENTS

       (1)    Same  instructions as ILA(4)-(11) above.

       (2)    Specific condition for control  of exhaust  from  & machine  subject to  this
             chapter, required by §63.322(b)(2)

       (3)    Specific  emission  control  requirement   for  equivalent   equipment   and
             procedures  used in place of refrigerated  condensers; based  on §63 323(b)

B.     TESTING AND MONITORING

       (1)    Same  instructions as II.B above

C.     RECORDKEEPING   REQUIREMENTS

       (1)    Same  instructions as II C above   Source subject  to §63.325(a)(l)-(2) only.

D.     REPORTING  REQUIREMENTS

       (1)    Same  instructions as II.D. above
                                                                           Page 6 of 7

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             This chapter covers provisions that apply new, reconstructed, or uncontrolled
             transfer  machines,  and  existing  refrigerated condenser-controlled   transfer
             machines with a potential  to emit of 10 tons per year or more.

A.    OPERATING  REQUIREMENTS

      (1)    Same instructions  as n.A(2)-(3) and  n.A(5)-(12) above.

      (2)    Specific  condition  for control  of exhaust  from a machine  subject to this
             chapter;  required by §63.322(b)(l).

B.    TESTING  AND MONITORING

      (1)    Same instructions  as II.B above.

C.    RECORDKEEPING  REQUIREMENTS

      (1)    Same instructions  as II.C above.

D.    REPORTING  REQUIREMENTS

      (1)    Same instructions  as n.D above.

      (2)    Specific  reporting condition  for  existing refrigerated  condenser controlled
             transfer machines  that  exceed the area  source perchloroethylene  usage limit;
             required by §63.325(e).
                                                                         Page 7 of 7

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