Document rxJ6dE41Nkzw2o8JGq4kYwXxr
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
June 21-23, 2017
RCRA
Hazardous Waste
United States Post Office Maintenance Facility
Maintenance Facility
2801 Washington Ave
Houston, TX 77007
2801 Washington Ave
Houston, TX 77007
Harris County Luis Trujillo luis.i.tru jillo_@ USPS.J;tOV
1Manager, Vehicle Maintenance
FRS Number: Identification/Permit Number: Media Number: NAICS: SIC:
TX2181599968
811111 4311
Personnel participating in inspection:
Joyce Johnson
US PEA
Angela Hays
US EPA
Donald May
USPS
David Moore
USPS
Inspector Inspector MVO Supervisor
214-665-8548 214-665-2285 713-861-0850 713-861-0235
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
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Title:
United States Post Office Maintenance Facility
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Author:
US EPA Region 6 Compliance Assurance and Enforcement Division, Dallas, TX
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Subject :
Inspection Report Resource Conservation Act
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Keywords:
Hazardous Waste, RCRA, USPS, Vehicle, Maintenance
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6ENFORM-019R7 (2/15/2017)
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Section I - INTRODUCTION
USPS / United States Postal Service Maintenance Facility Inspection Date 06/21/2017
PURPOSE OF THE INSPECTION
On June 21, 2017, I, Angela Hays, along with USEPA Enforcement Officer Joyce Johnson entered the United States Post Office Maintenance Facility at 9:30 a.m. for an unannounced Resource Conservation and Recovery Act (RCRA) inspection. We met with David Moore, Supervisor of USPS Maintenance Facility and Donald May, Manager of Vehicle Operations (HQ) for the Southern Region, Territory 5. Ms. Johnson presented her credentials and we conducted an opening conference. We explained that we were conducting a Resource Conservation and Recovery Act (RCRA) inspection. The scope of the inspection was a compliance evaluation inspection (CEI) to evaluate compliance with the United States Environmental Protection Agency's (USEPA) Resource Conservation and Recovery Act (RCRA) regulations for hazardous wastes generators. The inspection was completed June 22, 2017 with the closing conference held at approximately 3:30 p.m.
The purpose of the inspection was to determine the facility's generator status and check their compliance with regulations. In 1990, the USPS Maintenance Facility registered as a Small Quantity Generator (SQG) of hazardous waste. The facility disposed of waste codes of D001, D002, F003, and F005. In 2003, the facility changed their status to Conditionally Exempt Small Quantity Generator (CESQG) and listed waste codes D001, D002, D006, D007, D008, D018, D021, D027, D035, D039, D040, F003, and F005 wastes being generated. The facility changed status again in May of 2003 to nongenerator with no hazardous waste codes being generated (Appendix 3). Data reported on 9-30-2013, from the facility's Treatment Storage and Disposal Facility (TSDF), Safety-Kleen, showed this facility generating as a CESQG producing D001, D005, D006, D007, D008, and D018 wastes.
Due to lack of disposal documentation available during the inspection, the inspection team was unable to determine the generator status of the facility. Follow-up to this inspection is required.
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FACILITY DESCRIPTION
USPS / United States Postal Service Maintenance Facility Inspection Date 06/21/2017
The United States Postal Service Maintenance Facility is located at 2801 Washington Ave. Houston, TX 77007 in Harris County and has been in operation since 1980 (photos 283, 284, 285, 286 and map of the facility, Appendix 10). This facility employs 42 personnel from 9:00 a.m.to 5:00 p.m. The facility consists of a two story building, utilized for office and interior storage space, two exterior storage areas and two maintenance areas with bays. The facility focuses on routine vehicle service maintenance such as oil change, brake works, and tire replacement and maintenance for mail trucks, vans, and semi-trucks for the USPS Territory 5 area.
Section II - OBSERVATIONS
After Joyce Johnson and I explained the purpose of our visit to Mr. Moore and Mr. May we requested a tour of the facility. Mr. May granted permission for the tour and our need f documentation that included photographs. He also explained that the Manager of the Vehicle Maintenance Facility, Luis Trujillo, was on vacation and that we would be escorted by Mr. Moore. Mr. Moore clarified that he was a supervisor at the United States Postal Service Maintenance Facility but was not regularly in the maintenance shop.
Waste Streams
Used Oil The facility had several areas of oil filters draining (photos 222, 223, 224, 226, 233, 235, 236, 259, 264, 265). Within the first maintenance shop one of the oil filter drainage areas had oil and oily debris on the ground. The drum and filter drain area were not labeled (photos 222, and 223). During inspection the team observed used oil leaking from one of the white mail bins (photo 238). The used oil leaked onto the shelf and the floor (picture 239). The shelf and floor were wiped up before inspection team left (picture 240). The team also observed used oil remaining inside full drip pans within both of the maintenance areas (picture 261, 266). The oil pan in the second maintenance area had an oil spill on the floor (photo 266). The drip pans are containers used to accumulate used oil and were not labeled with the words "used oil". The pans were not being used to collect oil at the time of inspection, they were being used to retain used oil. The facility has a holding tank for used oil (photo 282, 282). The door on the holding tank allows for pump out (photo 278). The used oil tank was labeled with the words "used oil". The label is becoming difficult to read and should be replaced.
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Used antifreeze The facility has a holding tank for used antifreeze (photo 281). The door on the holding tank allows for pump out (photo 279, 280, 281, 282).
Brake Fluid During the inspection an opened bottle of brake fluid was observed (photo 220). The fluid in the bottle was not confirmed to be waste but appeared to be waste due to contamination of contents and warning labeling on the bottle. The team also observed an open pan of used brake fluid. The pan was not labeled and the team was unable to determine waste management at time of inspection (photo 250, 251).
Transmission Fluid During inspection the team observed an open bucket containing used transmission fluid. The container was not labeled and it was unclear as to how the waste would be managed during disposal.
Soiled Rags and debris Throughout the maintenance bays there were several piles of soiled rags. It was unclear if the rags were soiled with solvent, used oil, or another substance. It is also unclear of how the soiled rags are handled managed when spent (222, 225, 233, 242, 244, 245, 246, 248, 249, 250, 251). The team also observed soiled discarded gloves. It was unknown how the gloves will be handled in disposal (photos 247, 249, 250, 251)
Mop bucket During inspection the team observed a mop bucket with unknown contents (picture 236). The liquid in the bucket appeared dark in color with a sheen. The mop bucket will be discharged to the clarifier and then to the underground storage tank. The team requested a hazardous waste determination for this waste stream. The facility was unable to provide that waste determination.
Used battery accumulation area Used batteries are accumulated in the outside storage area (photos 254, 256). The batteries are not labeled with the words "universal waste" or with an initial accumulation date.
Records Review Records were unavailable at the time of the inspection, such as waste determinations and manifests. While at the facility, we reviewed available purchase orders from Safety-Kleen (Appendix 4), Safety Data Sheets (Appendix 5, 6, and 7), a Generator Waste Report provided by Clean Harbors dated 6/21/17 (Appendix 8), and documentation of a Waste Generator Investigation by the City of Houston on October 05, 2015 (Appendix 9).
The City of Houston commented that the facility should keep manifests for five years, clean out holding tank as needed and clean out acid neutralize as needed (appendix 9).
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The facility populated copies of purchase orders and shipping documents for Universal Waste, recycled oil, oil filters and Parts Washer Solvent (Appendix 4), Safety Data Sheets for Hulk System #20 Component A (Appendix 5), Hulk System #20 Component B (Appendix 6), Hulk System Degreaser #20 (Appendix 7), Clean Harbors Generator Waste Report (Appendix 8), and of The City of Houston Waste Generator Investigation Form (Appendix 9). Some of these products exhibit a characteristic according to their SDS. The inspection team requested waste determinations for these wastes when spent. The facility was unable to provide those determinations.
Although the facility previously registered as a non-generator, they have been generating hazardous waste in various amounts from month to month. Further documentation is required to determine month to month generator amount quantity. Current documentation calculates the facility as a Small Quantity Generator for the month of May 2017 and a large quantity generator for September 2013.
During the inspection and after the inspection, the team requested further information on the following waste streams. As the date of this report, the facility has not provided the requested information.
WASTE STREAM TRANSPORT DATE Cleaning Compounds
5/24/2017 Environmentally Hazardous Compounds
9/30/2013 Gasoline Waste
9/30/2013
AMOUNT ACCUMULATED 57 Gallon / 6.7 lbs per
gal 390 lbs
2730 lbs
TOTAL KG ACCUMULATED
173 KG
177 KG
1238 KG
WASTE DETERMINATION
NO
NO
NO
Battery Testing Area Batteries are tested in a dedicated room, on stainless steel tables, with buckets containing sodium bicarbonate underneath drainage pipes for spill containment (photos 211, 212, 213). The floor has residue from corrosive battery acid spills that drains into a sump (photo 214). It is unknown if there is a secondary containment unit on the sump. We were unable to access one of hatches for underground storage tank (photo 253). Following the inspection, the team requested hazardous waste determinations and waste disposal information for this waste stream.
Underground storage tanks The facility has underground storage tanks. One of the hatches to the tanks was inoperable. It is unclear if there was any material held in the tank at the time of inspection (photos 252, 253). The underground tanks normally hold oil and water from wash out area. The wash water is drained into the sump and
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pumped into underground tank. The tank is then pumped out by Safety Kleen. Following the inspection, the team requested a waste determination for this waste stream.
Parts washer The facility utilizes Safety Kleen parts washers (photos 218, 219, 228, 232, 263). The solvent product is purchased from Safety Kleen and the spent solvent is collected and managed by Safety Kleen. According to documentation received from the facility the last pick up before the inspection was collected on 5/24/17 in the amount of 57 gallons, and managed as a non-hazardous (Appendix 8). During inspection the team observed a spill around the parts washer located on the far back wall of the first maintenance facility (photo 232). This spill was not cleaned up at the time of inspection. Safety Kleen was at the facility the last day of inspection (photo 257). The inspection team requested waste determinations for the spent solvent and the spill residue.
Section III - AREAS OF CONCERN
Failure to label used oil containers with the words used oil o Oil pan containers o Used brake fluid o Used transmission fluid
Failure to label and date universal batteries Failure to provide records during inspection
o Manifests o Waste determinations Failure to properly document characterization of hazardous waste including o Spent parts washer solvent o Parts washer spill o Hulk System #20 Component A o Hulk System #20 Component B o Hulk System Degreaser #20 o Waste Gasoline
Section IV - FOLLOW UP
During the inspection the Vehicle Maintenance Manager, Luis Trujillo, was on vacation. We completed the facility inspection with the site supervisor, David Moore, but some details were unable to be explained until Mr. Trujillo was available. Further information has been requested in order to verify compliance with generator status and compliance with RCRA regulations. We are now waiting for documentation. Luis Trujillo was contacted for further documentation of the facilities shipments and
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waste determinations on 6/28/2017. Information was requested to be received within two weeks. Requested documentation was not received by Tuesday, July 12, 2017, nor to date. The following is a list of information requested from the facility.
Hazardous waste determinations for shipments of hazardous wastes on 09/30/2013 of Environmentally Hazardous Substances and Waste Gasoline, possible further documentation of disposal conditions.
Waste determination and disposal management for bicarbonate waste of batteries. Clarification of when and how the neutralizer pit cleaned out is managed.
Waste determination for step can waste. Waste determination and disposal management for soiled rags and gloves. Waste determination for 55-gallon drum of used oil and fuel filters (photo 264). Waste determination for oil/waste in underground tanks.
Section V - LIST OF APPENDICES
Appendix 1 2 3 4 5 6 7 8 9 10
Document Photographic Log Sign-in sheet Notice of Registrations Purchase Orders / Shipping Documents Safety Data Sheet for Hulk System #20 Component A Safety Data Sheet for Hulk System #20 Component B Safety Data Sheet for Hulk System #20 Component Degreaser Clean Harbors Generator Waste Report City of Houston Inspection Form Map of Facility
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Appendix 1 Photographic Log
76 pictures
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# 207- Storage of materials in flame proof locker 9
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#208 - Flammable Locker 10
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#209- MSDS Binder Cover 11
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#210 - Eye Wash / Shower Station 12
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#211- Battery Table 13
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#212 - Buckets of Sodium Bicarbonate under battery table 14
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#213 - Bags of Sodium Bicarbonate in Battery Room
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#214 - Drainage Area in Battery Room 16
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# 215 - Emergency number place card 17
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#216 - Posting of Emergency numbers on phone
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# 217 - Posting of emergency numbers on phone
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# 218 - Parts Washer ID
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# 219- Parts Washer in Bay 21
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# 220 - Uncapped Brake Fluid
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# 221 - Trash Can open with Disposed Solvents Residues 23
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# 222 - Filter Recycling / used oil receptacle #1 24
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#223 - Used oil collection 25
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#224 - Filter/ Used oil Drainage area #2
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#225 - Transmission Fluid station 27
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# 226 - Filter / Used Oil Drainage Are #3 28
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#227 - Spill Kit 29
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# 228 - Parts Washer #2
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# 229 - Windshield Wash 31
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# 230 - 32
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#231 - Unlabeled bucket of used Transmission Fluid
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#232 - Parts Washer #3 34
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# 233 - Filter / Used Oil Drain Area # 4
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# 234 Spill Kit
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# 235 - Filter/ used oil drain Area # 5
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# 236 - Filter / Used oil drain area # 5
# 237 - Used Oil Containment in washout bay
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# 238 - Used Oil Spill
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# 239 - Bin where oil spill occurred
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# 240 - Oil Spill Cleaned
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# 241 - Flammable Materials Cabinet
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# 242 - solvent soaked rags
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#243 - SAA Area
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#244 - Solvent soaked rags
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#245 - Solvent soaked rags
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#246 - Solvent Soaked Rags
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#247 - Solvent soaked rags
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# 248 - Solvent soaked rags
Is o e
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# 249 - Solvent soaked rags
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# 250 - Solvent soaked rags 52
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# 251 - Used Gear oil - unlabeled - Solvent soaked rags
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# 252 - Underground Storage Tank Cover 54
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# 253 - Underground Storage Tank Cover
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# 254 - Underground Storage area - Used Batteries not labeled
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# 255 - 55 gal drum containing used filters and rags 57
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# 256 - Wide shot of outside storage area 58
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# 257 - safety Clean truck
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# 258 - Trash Can unlabeled
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# 259 - Used Oil Drainage area # 8 61
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# 260 - Flammable Cabinet
# 261 - Full unattended used oil drip pan
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# 262 - Shop Area
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# 262 - Parts washer #3
# 262
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# 264- Filter collection Drum
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# 265 - Oil Filter Drain Area #9 67
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#265
# 266 - Unattended Spill From Oil Collection Container
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# 272 - MSDS Area for building and spill response area
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# 273 - Spill response area with rag containment
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# 272 - MSDS Area for building and spill response area 71
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# 273 - Flammable Storage area 72
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# 274 - Flammable Storage Area
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# 275 - Flammable Storage Cabinet
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# 278 - Waste Pump - oil
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# 279 - Waste Pump - AntiFreeze
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# 280- Waste Pump - oil
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# 281 - Waste Pump - antifreeze
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# 282 - pump enclosure
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# 283 - Front of Facility
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# 284 - Vehicle Entrance of Facility
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# 285 - Side of Facility
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# 286 - Front of Facility
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Appendix 2 Sign-in Sheet
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Appendix 3 Notice of Registration
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Appendix 4 Purchase Order Documents of PRM Solvent
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Appendix 5 Safety Data Sheet Hulk System #20 Component A
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Appendix 6 Safety Data Sheet Hulk System #20 Component B
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Appendix 7 Safety Data Sheet
Degreaser #20
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Appendix 8 Generator Waste Report
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Appendix 9 City of Houston Waste Generator
Investigation Form
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Appendix 10 Map of Facility Location
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