Identification of Performance Standards for Existing Stationary Sources
A Resource Document

This page last reviewed April 22, 2010

Under the California Clean Air Act, districts are to develop plans to attain the State ambient air quality standard for ozone by the earliest practicable date. In this area of the website, we summarize in question and answer format, the process underway to assist the districts in updating their plans to ensure inclusion of "every feasible measure." We also include summary tables which identify the performance standards for the first set of stationary source categories reviewed. For questions or comments or to request a hardcopy, please contact Dave Brown at (916) 324-1129.

TABLE OF CONTENTS

I. INTRODUCTION AND BACKGROUND  
II. EVERY FEASIBLE MEASURE  
  1. What is the definition of every feasible measure?  
  2. Why doesn't the Air Resources Board publish an every feasible measure list?  
  3. How do the RACT / BARCT requirements of the California Clean Air Act interface with the
every feasible measure requirement?
 
  4. Which districts have California Clean Air Act plans that include every feasible measure?  
III. IDENTIFICATION OF PERFORMANCE STANDARDS  
  1. Which stationary source categories were evaluated for performance standards?  
  2. What process did we use to identify the performance standards?  
IV. USE OF THE RESOURCE DOCUMENT  
  1. What is the benefit of having this resource document?  
  2. How can the districts use the performance standards data?  
  3. How can the ARB staff use the performance standards data?  
V. PUBLIC OUTREACH AND PROCESS FOR UPDATING DATA  
  1. What public outreach efforts were conducted to share the data with stakeholders?  
  2. How will this information be kept current?  
  3. What steps will be taken to keep abreast of new technologies?  


APPENDIX:IDENTIFICATION OF PERFORMANCE STANDARDS FOR EXISTING STATIONARY SOURCES

I. INTRODUCTION AND BACKGROUND
  The Air Resources Board (ARB) is proud of the progress which has been made over the past 50 years by the State and local air pollution control and air quality management districts' (district) air quality programs. The air we breathe today is healthier and smog episodes are less frequent and severe. However, despite this progress, there is a continuing need to achieve additional reductions of pollutants, especially those which contribute to ozone (volatile organic compounds and nitrogen oxides) and particulate matter, as the majority of the State's population resides in areas that remain nonattainment for these pollutants.
  Under the California Clean Air Act (CCAA), districts are to develop plans to attain the State ambient air quality standard for ozone by the earliest practicable date. The CCAA also requires these plans to demonstrate emission reductions of nonattainment pollutants or their precursors of at least five percent annually, averaged over three years, unless an ARB-approved alternative measure of progress is used. If a district cannot achieve these reductions, the CCAA provides that districts can develop approvable plans provided the plans commit to: 1) an alternative emission reduction strategy that is equal to or more effective than district-wide emission reductions in improving air quality; or 2) the implementation of every feasible measure on an expeditious schedule. This is a critical component of the CCAA. The Legislature wanted to ensure steady and expeditious progress towards meeting the more health-protective State standard but they also wanted to provide flexibility, knowing that in many cases the mature air pollution programs that were in place in California would be challenged by a rigid emission reduction target. Including the every feasible measure and expeditious adoption schedule requirements in the CCAA provided an alternative way of ensuring continuous progress in meeting the ambient air quality standards and underscored the expectation that meeting the ambient air quality standards would require the most effective measures possible, resulting in real emission reductions.
  The districts prepared the initial CCAA plans in the early part of this decade. At that time, all the districts submitting a plan committed to adopting every feasible measure. To assist the districts in this effort, the ARB staff developed a list identifying feasible measures that districts could use in developing their clean air plans. This list identified source categories for which regulations were clearly available and effective and represented a starting point for each district's analysis. It was provided with the expectation that, as regulatory programs moved forward and technology advanced, the every feasible measure list would undoubtedly change for each district.
  The districts are well on their way to implementing the plans. However, plans are dynamic and must be periodically updated to reflect changing circumstances. Under the CCAA, districts are to revisit the CCAA plans every three years, beginning in 1994. As part of this effort, the districts are to ensure that their plans continue to meet the every feasible measure requirement pursuant to the CCAA.
  To assist the districts in updating their current and future plans, we undertook an effort to identify potential areas of additional emission reductions that the districts can consider when updating their plans to ensure continued compliance with the every feasible measure mandate. As a result, we have identified performance standards for 24 stationary sources that can be evaluated for incorporation into the plans and implemented to maximize emission reductions. These performance standards are emission limits or work practice standards that, for the most part, have already been through a public review process. In the large majority of cases, the districts are already implementing these measures.
  In this resource document, we have summarized, in question and answer format, this effort to assist the districts in updating their plans to ensure inclusion of every feasible measure. We have also included, as an Appendix, the summary tables which identify the performance standards for the first set of stationary sources under review. As described later in this document, we intend to keep this information current by having ARB and district staff conduct periodic reviews of the performance standards compiled in the summary tables. Additional stationary source categories will be added when warranted.
II. EVERY FEASIBLE MEASURE
1. What is the definition of every feasible measure?
    The CCAA requires districts that are unable to achieve five percent annual emission reductions to demonstrate to the ARB's satisfaction that it has included every feasible measure in its plan and an expeditious adoption schedule. However, the CCAA did not define the term every feasible measure. When the initial CCAA plans were being prepared, we looked to related environmental statutes that offered useful definitions and precedent for defining this term. The most relevant definition found, and the one used, was in the guidelines issued to implement the California Environmental Quality Act (CEQA). In these guidelines, "feasible" is defined as:
    Capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors." (14 California Code of Regulations, Section 15364)
    Thus, we interpret the adoption of every feasible measure to mean that, at a minimum, a district consider regulations that have been successfully implemented elsewhere. They should also consider going beyond what has already been accomplished by evaluating new technologies and innovative approaches that may offer potential emission reductions. Further, districts should consider not only technological factors, but also social, environmental, economic (e.g., cost-effectiveness), and energy factors which prevail in the district, along with the resources realistically available to the district to adopt, implement, and enforce the measures.
2. Why doesn't the Air Resources Board publish an every feasible measure list?
    We believe it is unlikely that a "list" of every feasible measure could be developed that provides detailed information on control strategies and would meet each districts' needs for fulfilling the CCAA every feasible measure requirement. In 1991, the ARB did publish a "list" that represented every feasible measure. However, this list did not identify specific regulatory requirements that should be included in each plan; it only identified the source categories for which the districts could consider incorporating a measure in the event they had that source category in their district. This is consistent with the ARB's philosophy that "feasible" must ultimately be defined by each district based on technological, social, environmental, economic, and energy factors that prevail in the district, along with the resources realistically available to the district to adopt, implement, and enforce the measures. This identification of performance standards can be used in the same fashion; for those districts that have a source category in their district that is evaluated in this document, they can review the performance standards, taking into account the above mentioned factors, to determine if improvements to their CCAA plan can be made.
3. How do the RACT / BARCT requirements of the California Clean Air Act interface with the every feasible measure requirement?
    The CCAA requires districts which have been designated nonattainment for the State ambient air quality standards for ozone, carbon monoxide, sulfur dioxide, or nitrogen dioxide to prepare and submit plans for attaining and maintaining the standards. The CCAA also specifies various measures which, to the extent necessary, must be included in the district plans. These measures include the use of best available retrofit control technology (BARCT) and reasonably available control technology (RACT) on existing stationary sources.
    The required use of BARCT for existing stationary sources is one of the specified (feasible) measures. The CCAA defines BARCT as an emission limitation that is based on the maximum degree of reduction achievable, taking into account environmental, energy, and economic impacts by each class or category of source. Unfortunately the CCAA does not define RACT. However, its required use is only to be considered for small sources in moderate areas.
    In developing their plans, each district determines which measures are necessary to include, as well as the specific details of each included measure. As guidance to districts developing stationary source control measures, the ARB publishes formal RACT / BARCT determinations, developed in conjunction with the California Air Pollution Control Officers Association (CAPCOA). The number of source categories addressed by these formal determinations is limited, and some of them may be several years old and not be representative of current control capabilities. This identification of performance standards is intended to complement the existing RACT / BARCT process while providing further assistance to districts in developing or revising control measures for stationary sources within their jurisdiction.
4. Which districts have California Clean Air Act plans that include every feasible measure?
    As shown in Table I, there are 21 districts that have plans describing how they will meet the California ambient air quality standards. No district has been able to demonstrate a five percent annual reduction in ozone precursors. Therefore, every district's plan is evaluated on the basis of demonstrating adoption of every feasible measure. (1)
   
Table I
California Districts with California Clean Air Act Plans
San Diego County APCD Bay Area AQMD
South Coast AQMD Mojave Desert AQMD
Monterey Bay Unified APCD Kern County APCD
San Joaqun Valley Unified AQMD Ventura County APCD
Sacramento Metropolitan AQMD Placer County APCD
Yolo-Solano AQMD El Dorado County APCD
Santa Barbara County APCD San Luis Obispo County APCD
Imperial County APCD Butte County AQMD*
Colusa County APCD* Feather River AQMD*
Glenn County APCD* Shasta County AQMD*
Tehama County APCD*  
   * Butte County, Feather River, and Shasta AQMDs and Colusa, Glenn, and Tehama APCDs have one plan that covers all the Upper Sacramento Valley Districts.
III. IDENTIFICATION OF PERFORMANCE STANDARDS
1. Which stationary source categories were evaluated for performance standards?
    There are over 80 stationary source categories that are potential candidates for the districts to consider when updating their plans. These can be categorized into three tiers. The 24 source categories in Tier I are the first to be addressed by ARB staff and are the subject of this resource document. These categories were selected for review based on their emissions and emission reduction potential. The Tier I stationary source categories are listed in Table II along with the proposed Tier II and III categories. Based on the feedback at public workshops and discussions with district staff, we do not plan on evaluating the Tier II or III categories at this time.
   
Table II
Tier I, II, and III Stationary Source Categories
Tier I Stationary Source Categories

Adhesives and Sealants Aerospace Coatings Architectural Coatings and Industrial Maintenance
Auto Refinishing Bakery Ovens Fugitive Emissions from
Chemical Plants
Fugitive Emissions from
Oil and Gas Production 
Fugitive Emissions from Petroleum Refineries Gasoline Terminals
and Bulk Plants
Graphic Arts Industrial Boilers Large Water Heaters
and Small Boilers
Marine Coatings Metal Parts and Products Coatings (Non-Architectural) Pleasure Craft Coating
Operations
Polyester Resin
Operations
Polymeric Foam Product Manufacturing Portland Cement Kilns
Refinery Boilers Restaurants, Chain-Driven Charbroilers Small Industrial Boilers
Solvent Cleaning and
Degreasing
Surface Coatings of Plastic
Parts and Products
Wood Products Coating
Operations

Tier II Stationary Source Categories

Air Stripping Operations Can and Coil Coatings Coatings and Ink
Manufacturing
Control of Emissions
from Steam Drive Oil
Production Wells
Control of Emissions from
Cyclic Oil Production Wells
Cutback Asphalt
Fiberboard Manufacturing Glass Melting Furnaces Incinerators
Magnet Wire Coating
Operations
Marine Vessel Ballasting
and Housekeeping
Marine Vessel
Loading Operations
Organic Chemical
Manufacturing
Paper, Fabric, and Film
Coating Operations
Plastic, Rubber,
and Glass Coatings
Polymer Resin
Manufacturing
Residential Heaters Residential Water Heaters
Screen Printing Semi-Conductor
Manufacturing
Spray-Coating Operations
Stationary Gas Turbines Surface Coating of Large
Appliances and Metal
Furniture
Usage of Solvents
Utility Boilers (Electrical) Vegetable Oil Manufacturing VOC Waste Disposal
Wood Flat Stock and Paneling Coatings Operations Stationary IC Engines  

Tier III Stationary Source Categories

Aircraft Fuel Transfer
into Storage Tanks
Clean Fuels for Fleets Covers for Sumps, Pits, and Wastewater Processing Equipment
Crude Oil Pipeline Heaters Flexible and Rigid Disc Manufacturing Floating Roof Storage Tanks
Fossil Fuel Steam
Generator Facilities
General Exemptions Kelp Processing Plants
Landfill Emissions Leather Processing Operations Livestock Feed Yards
Motor Vehicle Assembly
Line Coating Operations
NOx from Heat Transfer Operations Oil Field Steam Generators
Oleum Transfer Operations Organic Liquid Loading Paper Treating Operations
Petroleum Solvent
Dry Cleaners
Petroleum Storage
Tank Degassing
Pharmaceutical and Cosmetic Manufacturing Operations
POTW Emissions Refinery Vacuum Producing Systems, Wastewater
Separators, and Process
Unit Turnarounds
Residential Wood Combustion
Rubber Tire Manufacturing Operations Spillage and Leaking of VOC Solid Fuel-Fired Boilers
Solvent Storage Surface Preparation and
Cleanup
Surfactant Manufacturing
Synthetic Solvent
Dry Cleaning
Vapor Recovery at Gasoline Dispensing Facilities Wineries
2. What process did we use to identify the performance standards?
    We followed a three-step process when identifying performance standards for a given source category. First, we reviewed all readily available source specific rules and guidance documents pertaining to a given source category to select those that contained the most effective performance standards. The determination of "most effective" was limited to an analysis of which requirements might go the furthest in reducing emissions. It was also our desire to select only those performance standards that had been subject to a full public process. Hence, we limited our review to current prohibitory rules that are being implemented and guidance documents such as Suggested Control Measures, RACT / BARCT guidelines, and U.S. EPA Control Technique Guidelines.
    Once the rules or guidance documents that contained the most effective performance standards were selected, we conducted a side by side comparison of the rules. These comparisons are shown in the tables included in the Appendix.(2) The final step was to identify the most effective performance standard(s) for the source category under review (identified with an "x" in the summary tables). To select the most effective performance standard, staff reviewed the performance standards identified for each regulated component within a source category and identified the performance standard that would result in the highest level of control that had been achieved in practice. In most cases, it was possible to identify one performance standard that represented the most effective performance standard; however, there were circumstances where this was not possible. For example, in some cases, each rule or measure compared had the same performance standard for a particular regulated component. In that case, there was not "one" rule or measure that could be identified as having the most effective performance standard - each of the measures had the "best" and necessarily, each performance standard was marked with an "x." In the large majority of cases, the performance standards are already being implemented. However, there are a few standards that were identified that have future effective dates. For these standards, while the technology that could be used to meet the performance standard would have been identified during the rule development process, the standard will not be enforced until the future date has passed.
    We need to emphasize that this process was not designed to select what the ARB staff believe is the most appropriate rule for a source category or to provide the level of detail necessary to propose a new standard. Nor should one assume if a district rule is listed as a reference for a particular performance standard that it will achieve the most emission reductions. The overall effectiveness of a rule will depend on many components including the test methods, averaging times, applicability, exemptions, and technical definitions. Our goal was to identify performance standards that are currently achieved in practice, not to evaluate a rule in its entirety. We also did not address cost-effectiveness in our comparison - a very important factor to consider when determining the feasibility of a rule. When adopting a rule or guidance measure, air quality staff are required to consider and provide data on the cost-effectiveness of the measure. However, because there has not been a consistent approach used to estimate cost-effectiveness and, in many cases, the data are unique to each area, we believed that providing cost-effectiveness data would not be beneficial and would be subject to misinterpretation. The effort would also exceed our resources available to complete such an analysis.
IV. USE OF THE RESOURCE DOCUMENT
1. What is the benefit of having this resource document?
    We believe this summary of performance standards offers many benefits as California air quality agencies continue to work together to realize our clean air goals. This resource document provides present day data which identify performance standards that are currently achievable and summarizes a significant volume of data into a manageable and concise document. Districts that decide to include identified performance standards into a plan or stationary source rule will have the knowledge that the performance standard has achieved emission reductions elsewhere, and that technology is available to meet that performance standard. This information will also benefit both ARB and district staff by reducing the amount of time spent on reviewing existing rule databases and guidance documents. It is worth reiterating, however, that this resource document is a tool, not a guideline or mandate. The ARB staff do not intend to mandate adoption of performance standards identified in this document that are determined to be not feasible by a given district.
2. How can the districts use the performance standards data?
    We believe the district staff can use the information on performance standards to support efforts to continue progress toward meeting the federal and California ambient air quality standards. This information will be useful during the planning process, such as revising and updating air quality plans, preparing rulemaking calendars, and developing rules. As an example, we propose that the information provided on performance standards be used as a starting point for each district's review and update of their plan to verify that it still incorporates every feasible measure as required by the California Clean Air Act. It may also prove useful as a resource when districts revisit or amend stationary source rules by providing ideas on ways to strengthen rules to achieve additional emission reductions. District staff should not assume, however, that because a performance standard is listed in a table, it is appropriate for source categories in every district. These performance standards should be considered a starting point for discussions with affected sources as well as with the other districts that have already incorporated a performance standard in a prohibitory rule. Each district will need to evaluate the appropriateness of a particular standard, taking into consideration cost-effectiveness and other district-specific factors as well as the overall rule requirements prior to adopting a final rule.
3. How can the ARB staff use the performance standards data?
    We can use the information on performance standards to review air quality plans and plan revisions, district rulemaking calendars, and rules submitted by the districts for ARB comment. This information helps us provide consistent rule and plan reviews and allows staff to more easily identify areas for improvement or further reductions in either the plans or prohibitory rules. Consistent with our past practices, we will work with each individual district on any suggestions for improvement that are based on the information in the resource document. In addition, we do not intend to require every district to adopt each performance standard identified; rather, we expect them to evaluate the appropriateness of the performance standards for implementation in their district. As mentioned above, this will entail looking at district-specific factors such as emissions, source characteristics, cost-effectiveness, and technology availability. In the event their evaluation demonstrates they can realize cost-effective emission reductions, we will support their efforts to adopt the performance standards deemed feasible.
    In addition, with the adoption of the new federal ambient air quality standards in 1997, the U.S. EPA will designate new federal nonattainment areas beginning in 1999, and additional emission reductions are likely to be required in existing nonattainment areas. New federal attainment plans for ozone will be required by 2003, with implementation of the plans and attainment of the standards through 2010 and beyond. The districts and ARB will soon be immersed in preparing the federal plans to meet the new ozone standard and information contained in this resource document may be useful in that exercise.
V. PUBLIC OUTREACH AND PROCESS FOR UPDATING DATA
1. What public outreach efforts were conducted to share this data with stakeholders?
    This information was presented in draft form to the ARB at its March 1998 public hearing. At that time, the Board supported this project. While the majority of the information presented in the summary tables has already been through the public review process prior to its implementation as part of the adoption process for the rules and guidance documents, we wanted to share it with the Board as well as conduct public workshops with stakeholders and obtain district comment prior to finalization of the draft. As such, we pursued numerous avenues to obtain comment that could then be reflected in the final version of the  esource document. We worked closely with district staff, both through the CAPCOA Planning Managers and Board of Directors and also formed a district / ARB work group to discuss the information. This group met by conference call on three occasions between March and October 1998. We also conducted three public workshops. These were held in Diamond Bar, the San Joaquin Valley (Bakersfield, Modesto, and Fresno), and in Sacramento during the month of August 1998. Each workshop was attended by approximately 20-25 people representing local industry representatives, consulting firms, and districts. At the workshops, ARB staff provided a short presentation on the resource document and solicited comment from the attendees. This final version of the resource document reflects modifications made in response to comments made at the workshops and by district staff during the district / ARB work group conference calls.      
2. How will this information be kept current?
    During the outreach efforts, the stakeholders and district staff frequently suggested that the resource document be kept current and up-to-date. We agree that this is important. To keep the information current, we developed a process that can be implemented concurrent with the existing rule review process. Each time a district adopts or amends a prohibitory rule for a source category included in the resource document, they will notify us if modifications to the resource document are necessary. In cooperation with the district staff, the ARB staff will update the tables and any changes will be reflected in the version of the resource document located on the ARB website (http://www.arb.ca.gov/ssps/ssps.htm). We have added a date to each table in the appendix which will reflect the date of the most recent update for that specific category. We also intend to conduct at least annual reviews of the data to determine if additional modifications are needed. Comments can be provided at any time on the web version, and a location on the site is provided for submitting comments to the ARB. The information is also available electronically via CD-ROM or diskette.
3. What steps will be taken to keep abreast of new technologies?
    There is clearly the need to go beyond what has already been accomplished and continue the search for new technologies that will achieve additional emission reductions further out in the future. Most populated areas in the State still experience days where the State and federal ambient air quality standards for ozone are exceeded and the new federal ozone standard will provide new challenges for some areas. It is important for air quality agencies to research, encourage, and foster new technology that holds promise for additional emission reductions of air pollutants. In the draft version of this resource document we had included, for many source categories, tables describing emerging technologies that were not widely used or required in practice, but offered potential for additional emission reductions in the next three to five years. Sources for this information included Best Available Control Technology / Lowest Achievable Emission Rate Clearinghouses, symposia, technical literature, and manufacturers of control technology.
    During our public outreach, the following concerns were raised about the emerging technology information: 1) the information was sometimes dated and not particularly comprehensive or accurate; 2) the information was available elsewhere (e.g., BACT Clearinghouse); and 3) the draft did not always include discussions of cost-effectiveness, the stage of development, or whether the technology was proven. While many stakeholders recommended deleting the section as presented in the draft document, they encouraged the ARB to develop an alternative approach to address emerging technologies. As such, in the final document, we have omitted the emerging technology section. As an alternative, we are considering ways that ARB staff could identify new technology information such as sponsoring regular technology conferences, conducting informal focused workshops on specific source categories, and developing a website that provides links and telephone contacts to information about new technologies. We welcome input on these and any other ideas that we might consider in presenting new technology information.
1 Both Monterey County and San Luis Obispo County APCDs recently provided plan updates in 1998 that included an alternative strategy for demonstrating the level of emission reductions needed to achieve the State ozone standard based on an ozone design value. (Guidance on Estimating Emission Reductions Needed to Attain State Standards and for Determining Area Classifications in Response to the California Clean Air Act, October 1990)
2 Two tables are included in the Appendix for each source category reviewed. Table I contains the side-by-side comparison of the performance standards for each regulated component within a source category. Table II is a continuation of Table I that lists the applicability, the more notable exemptions, and additional comments about each rule or measure.


APPENDIX

Notes on Tables

For the purpose of keeping this summary concise, there are many instances where a district's rule with equivalent performance standards for a particular subcategory is not mentioned. If a rule is cited as most effective, the rule is considered at least as effective and not necessarily more effective than other district rules.

In the following tables, an "x" is placed in the small column to the left of the most effective performance standard. "Most effective" can be defined as the best control efficiency, or resulting in the greatest percentage of emission reductions from the particular source category (without taking into account other factors such as exemptions and applicability). In many cases, more than one "x" is indicated because performance standards in different district rules are equivalent. For instance, two districts may have the identical emission limit, measured in grams / liter, for a coating category. Occasionally, more than one "x" may be indicated in cases where performance standards may not be identical, but it is hard to reach any definitive conclusion as to which rule is most effective. Certain tables include an 'nq" in the column on the left, meaning 'not quantifiable."

For each source category, there is a Table I and a Table II. Table I presents the emission limitation, control efficiency, or other similar measure. Table II lists exemptions, applicability, and comments. Also, where there are more than five references, the tables are broken into two parts (e.g., Table I (1 of 2); Table I (2 of 2)).

The links below provide access to individual source category types in PDF format. The hypertext link specifies the file size of each file format for each summary table. The links below provide access to individual source category types in PDF format. The hypertext link specifies the file size of each file format for each summary table. In addition to these individual files, we provide the entire set of files in either format as a single downloadable compressed document. To access ALL of these summaries in a single zip-compressed file, download either of the links: PDF - 1,110K .

TABLE OF CONTENTS
SOURCE CATEGORY ADOBE ACROBAT FORMAT
Adhesives and Sealants 40K
Aerospace Coatings 276K
Architectural and Industrial Maintenance Coatings 46K
Auto Refinishing 52K
Bakery Ovens 26K
Fugitive Emissions from Chemical Plants 121K
Fugitive Emissions from Oil and Gas Production 88K
Fugitive Emissions from Petroleum Refineries 49K
Gasoline Terminals and Bulk Plants 16K
Graphic Arts 102K
Industrial Boilers 14K
Large Water Heaters and Small Boilers 13K
Marine Coatings 34K
Metal Parts and Products (Non-Architectural) 49K
Pleasure Craft Coating Operations 13K
Polyester Resin Operations 121K 
Polymeric Foam Product Manufacturing 60K
Portland Cement Kilns 11K
Refinery Boilers 10K
Restaurants, Chain Driven Charbroilers 17K
Small Industrial Boilers 10K
Solvent Cleaning and Degreasing 11K
Surface Coating of Plastic Parts and Products 40K
Wood Product Coatings 225K


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