ML20212E996
| ML20212E996 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/29/1997 |
| From: | Zinke G Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20212F002 | List: |
| References | |
| GAZ-97-002, GAZ-97-2, MN-97-118, NUDOCS 9711040143 | |
| Download: ML20212E996 (11) | |
Text
O-i MaineVankee RELIABLE ELECTRCfY FOR MAJNE SINCE 1972 PCL BOX 408. WISCASSET, MAINE 04578. (207) 882 4321 October 29,1997 MN 97-118 GAZ-97-002 UNIT 8D STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C. 20555 e
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b)
Maine Yankee Emergency Plan, dated December 1,1992 (c)
Maine Yankee Letter to NRC (MN-97-89) dated August 7,1997 (d)
Maine Yankee Letter to NRC (MN 97-87) dated July 29,1997
Subject:
Change to the Maine Yankee Emergency Plan Gentlemen:
Pursuant to 10CFR50.4, please Ond enclosed Change No. 97-05 to the Maine Yankee Emergency Plan. This change has been made in accordance with the provisions of 10CFR50.54(q).
Change 97-05 includes the following changes to the Maine Yankee Emergency Plan: 1) The requirement for a semi annual dril' involving the post accident sampling system (PASS) is removed;
- 2) The stafling of the Emergency Response Organization is modified; 3) The requirement for the conduct of an annual audible siren test is removed; 4) The requirement for maintenance of an emergency response data system (ERDS) is removed; 5)The process used to provide educational infonnation on radiation to the public is modified; 6) The process for notifying the state of Maine once the site and state emergency centers are operational is modified; and 7) Several miscellaneous changes are also included.
Maine Yankee submitted a Certification of Permanent Cessation of Operations and Certification of Pennanent Removal of Fuel on August 7,1997 to the NRC, Reference (c). Based on our evaluation -
in Attachment A, we have determined that these modifications are consistent with the reduced risk associated with the plant's permanently defueled condition.
A descripti?n of the plan changes, along with informational copies of revised pages of the Emergency Plan, are provided in Attachment A. A complete set of revised pages will be distributed under separate cover to all those on the controlled distribution list for the Maine Yankee Emergency Plan.
' This change has been reviewed by the Plant Operations Review Committee, it has been determined that this change to the Maine Yankee Emergency Plan:
'(1) does not deen:ase the effectiveness of the Plan resulting in the loss of reasonable assurance that adequate protection can and will be taken in the event of a radiological emergency as
- required by 10CFR50.47(a).
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MaineYankee fUNITED STATES NUCLEAR REGULATORY COMMISSION MN-97-I l 8 --
Page Two L
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- Attention
- Document Control Desk '
- (2) does not-result in thi loss of ability to meetLany of the standards described in:
110CFR50,47(b) or any NRC approved alternatives to these requirements.'-
.(3) does not delete or contradict any regulatorv requiremeni.
We have discussed the relevant aspects of these Emergency Plan changes with representatives of the~
^ Maine Emergency Management Agency (MEM A) who concur with the changes contained herein.
We trust this information is satisfactory Should you have any questions regarding this information,.
- please contact me.-
n Very truly yours, 9g/
-Q George A.Zinke Manager, Regulatory Affairs
- GDW/mwr
' Attachment
- c:
' Mr. Hubert Miller (2 copics)
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' Mr. R.A. Rasmussen
- Mr. Mike Webb Mr. John H. Lusher -
Mr. P.J.' Dostic, SNSI Mr. John W. Libby, Director, Maine Emergency Management Agency
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ATTACHMENT A
SUMMARY
OF CilANGES TO Tile MAINE YANKEE EMERGENCY PLAN I
1.0 INTROL1UCTION On August 7,1997, Maine Yankee submitted "Cecifications for Permanent Cessation of Power Operal' n and Pemianent Removal of Fuel from the Reactor" pursuant to 10CFR50.82(a)(1)(i) and i
(ii). With the docketing of this submittal, Maine Yankee was no longer authorized to operate the reactor or to place fuel in the reactor vessel in accordance with 10CFR50.82. In the defueled condition, there are no longer any credible design basis accidents associated with an operating plant from sttutup through full power operat!an. The design basis accidents relative to a defueled facility are a small subset of those considered for an operating facility. With the plant having been shut down since Dnember 1996, the potential source term associated with the remaining design basis accidents has been significantly reduced. Therefore, with the plant in a pennanently defueled condition, coupled with the duration that the plant has been shut down, the risk to the pubile associated with the plant has significantly decreased and is continuing to diminish. By mid 1998, offsite response capability is no longer expected to be warranted.
Many of the Emergency Plan provisions, both onsite and offsite, which were appropriate for an operating phmt are no longer appropriate. The Emergency Plan and its implementing procedures will be periodically reviewed during the decommissioning process to ensure that the onsite and offsite resources are focused on the appropriate activitms. This document contains summaries of changes to the Emergency Plan which are appropriate at this time. Changes which involve exemptions to Commission regulations are being submitted separately for NRC approval.
2.0 DESCRIPTION
OF Cil ANGES 2.1 PASS DRILL Sections 7.3,l.2,8.1.3.c.2 and Tabla 6 2 of the Maine Yankee Emergency Plan are being modified to temove the requirement for a semi annual drill involving the analysis of in plant samples including the use of the Post Accident Sampling System.
2.2 EMERGENCY RESPONSE ORGANIZATION (ERO) STAFFING Sections 5.4,8.1.2, Figure 5 5, and Table 61 of the Maine Yankee Emergency Plan are being modified to reflect changes in the Emergency Response Organization (ERO). The following positions have either been consolidated or eliminated from the ERO: (1) Site Contact; (2)
Communications Coordinator in the EOF; (3) EOP Advisor in the TSC; (4) Nuclear Safety Advisor in the TSC; (5) Contrcl Room Communicator in the TSC; (6) EOF Radio Operator; (7) EOF Operations Advisor.
13 ANNUAL AUDIBLE SIREN TEST Sectior. 8.1.3 of the Maine Yankee Emergency Plan is being modified to remove the requirement for an annual audible test of the Public Emergency Alerting System.
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4 2.4 EMERGENCY RESPONSE DATA SYSTEM (ERDS)
Section 7.2.3.d of the Maine Yankee Emergency Plan is being.nodified to remove the requirement for the Emergency Response Data System.
2.5 PUBLIC INFORMATION Section 8.5 of the Maine Yankee Emergency Plan is being modified to change the method used to provide educational infonnation to the public on radiation.
2.6 STATE OF MAINE NOTIFICATION Sections 5.4,6.2,7.2.1,7.2.2 and Figure 61 are being mo 'ed to describe the change to the State of Maine notification process for emergency classifications, classification changes, and protective action recommendations once the state and on site emergency centers are operational, 2.7 MISCELLANEOUS CllANGES Pages 6.16,6.19 and Figure 7-1 have been modified to change the name of the Energy information Center to the Career Conter.
Figure 5 4 is being revised to eliminate reference to Offsite Dosimetry Assistants in the EOF.
Section 6.4 is being modified to change emergency operating procedures to abnonnal operating procedures.
3.0 JUSTIFICATION OF Cl{ANGES 3,1 PASS DRILL Sections 7.3.1.2,8.1.3.e.2 and Table 6 2 of the Maine Yankee Emergency Plan require a semi annual drill involving the analysis ofin plant samples including the use of the Post Accident Sampling System (PASS), Guidance provided in NUREO 0654 Rev.1 in section N.2.e(2) requires periodic drills involving the use oithe post accident sampling system. The PASS is designed to take samples fmm the reactor coolant system. With the plant in a pemianently defueled condition, all the fuel has been removed from the reactor vessel. It is no longer possible for a design basis accident to occur which could affect the reactor coolant system and warrant the use of the Post Accident Sampling System. The use of this system is not required to analyze or to mitigate the effects of the remaining design basis accidents to which the plant continues to be susceptible. Therefore the requircinent for a semi aimual PASS drill can be deleted without reducing the eifectiveness of the Emergency Plan in the defueled plant condition.
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e 3.2 EMERGENCY RESPONSE ORGANIZATION (ERO) STAFFING Each ERO position that has been changed is discussed benw.
OfficC_OffilitIEtaty_Dirceior The duties of the She Contact position, were consolidated with the functions of the Emergency Director's Assistant. The Site Contact provided a point of contact to converse with the Maine Yankee Technical Representatives at the State EOC in Augusta, providing up to-date plant information. Because the range of accidents that can occur has been substantially reduced, there is substantially less infonnation that must be gathered by the Emergency Director's Assistant (reducing his responsibilities) and subst atlally less infonnation that would be transmitted to the state EOC via the site contact to the Maine Yankee technical representatives and media representatives. One person can now adequately handle both functions. This position was an auxiliary position, not recommended by Table B 1 of NUREG 0737 and not required by the Maine Yankee Emergency Plan for immediate emergency mitigation or assessment support activities.
ItthilltAUiupport Center The EOp advisor position has been eliminated, as all Emergency Operating Procedures (EOPs) and Functional Restoration Procedures (FRPs) have been cancelled und are no longer available. It is therefore no longer necessary to stalTa postion in the TSC assigned to monitor control room use of EOPs and FRPs, and ensure that (1) the control room is implementing the correct steps of the co:Tect EOP/FRP, or (2) look ahead in the EOP/FRP set to detennine if roadblocks may lie ahead for the operators.
The position of Nuclear Safety Adviser has been climinated, as all critical safety functions and critical safety function status trees previously monitored by this position have been canceled since they are no longer needed for the range of now possible design basis accidents. All necessary monitoring of spent fuel pool criticality and reactor physics will be adequately handled by the Reactor Engineering representative in the TSC.
The positions of NRC Communicator / Log Kecoer. and Trend Status Board keeper have been consolidated. The NRC communicator / log keeper sits next to the status board keeper and can assume his function. The range and breadth of potential plant parameters to be monitored, posted on a status board, logged in a center log, and communicated to the NRC, have been substantially reduced from those many parameters necessary to be monitored for potential accidents associated with an operating power plant, to a minimal set of parameters associated with potential accidents for a pennanently defueled plant.
The position of Control Room communicator has been climinated from the TSC. Communications needs between the control room and the TSC for an operating plant at power required an Operations stalTmember assigned full time to talk to the control room and to either provide instructions from the TSC or obtain information for the TSC. This function can now be handled on an "as needed" basis by the Operations Coordinator or another TSC staff member.
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OpetallusiSupparLCrnier The number of Response Team Coordinators has been reduced from three to two. With a substantially reduced work scope for the OSC, to dispatch damage control teams to essentially one location (the fuel building) instead of multiple plant locations, it has been detennined that two response team coordinators can adequately provide approprir.te team briefings, mission planning and monitoring, and debriefmss for the range of accidents now possible.
The positions of Communleations Aide and Status Board Keeper have been combined into one position. These two functions are co located in the OSC, as the OSC radio and the status board are located within a matter of feet of each other. Due to the reduced scope and anticipated workload to be assigned to the OSC, with fewer teams to track via radio and status board, one person could easily handle both functions. These positions were auxiliary positions, not recommended by Table 11 1 of NUREO 0737 and not required by the Maine Yankee Emergency Plan for immediate emergency mitigation or assessment support activities.
Enittgency Opera 11ons Facillly The position of Radio Operator was consolidated with the Off Site Radiological Coordinator (ORC).
The ORC coordinates the assembly, briefmg, and direction of offsite monitoring teams to pre-designated locations. The ORC stays near the radio system so that he may communicate with his teams, provide plant status update infonnation and any changes it. monitoring strategy to the teams, and receive monitoring data from the teams. As the number of teams is being reduced (see below) from 3 teams to 2 teams, and because the anticipated need to conduct offsite monitoring for a fuel pool accident is substantially less than the need to conduct monitoring for a LOCA, these positions can be combined, such that the ORC can assume the duties of the radio operator. This position was an auxiliary position, not recommended by Table B 1 of NUREG 0737 and not required by the Maine Yankee Emergency Plan for immediate emergency mitigation or assessment support activities.
The number of Field Monitoring Teams (FMTs) has been reduced from 1. cams of two people cach to two teams of two people cach. As the anticipated need to conduct off4te monitoring for a fuel pool accident is substantially less than the anticipated need to conduct monnoring for a LOCA, and because the State of Maine maintains the ability to put two or more FMTs into the field around Maine Yankee, a reduction isjustified, as two teams can adequately monitor the environs around Maine Yankee to be abic to continually assess the magnitude of a release. The Emergency Plan (section 6.3.3) notes that " additional teams may ' c assembled as needed"; this statement remains o
true, in that the EOF is not restricted to dispatching only two FMTs.
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4 The EOF Onerations Advisor position has been eliminated. The Operations Advisor was used to assist the PAR /EAl, advisor in the EOF in obtaining up to date plant status infonnation from the TSC, by talking to the TSC and by listening in on a TSC/ Control Room hotline. With the need for minute by minute operational data in the EOF reduced dramatically, the PAR /EAL advisor can readily obtain the infonnation he needs to make infonned recommendations regarding protective action recommendations and EAl changes to EOF management. The EOF and TSC are located in adjacent rooms, facilitating the How ofinfonnation. This position was an auxiliary position, not recommended by Table 11 1 of NUREO 0737 and not required by the hiaine Yankee Emergency Plan for immediate emergency mitigation or assessment support activities.
i The positions of Ilotline.Qperator. Telecopier Oncrator. and Status Board Keenet, have been consolidated into one position. The llotline operator used to be responsible for ensuring the state of hiaine received noti 6 cation wi,hin 15 minutes of the declaration of an emergency, a re-classi6 cation of an EAl., or a new or updated Protective Action Recommendation (PAR). These noti 6 cation functions (to the state EOC when staffed, and to the State Police until the State EOC is staffed) are now accomplished by the Emergency Director's Assistant. In addition, fewer fonns are now faxed to the State EOC, by mutual agreement between the State of hiaine and hiaine Yankee, thereby reducing the workload of the fax operator. The remaining hotline, fax and status board duties can be perfonned by one person. These positions were auxiliary positions, not reco nmended j
hy Table B 1 of NUREG 0737 and not required by the hiaine Yankee Emergency Plan for immediate emergency mitigation or assessment support activities.
The positions of Administrative Sunnort hinnager and Communications Coordinator are being merged. The Administrative Support hinnager cat, assume the duties of the Communications Coordinator, as the Communications functions have been reduced as described above. The Emergency Director is responsible for state noti 6 cations, and because of the reduced risk, substantially fewer communications requirements are expected from the EOF given the reduced work load due to the substantially reduced number and elTects from design basis accidents.
3,3 ANNUAL AUDIBLE SIREN TEST Section 8.1.3 of the hiaine Yankee Emergency Plan requires an annual audible test of the Public Emergency Alening System (PEAS). The annual test is used as one part of the testing and maintenance program, in conjunction with monthly and quarterly tests and the remote feedback system, to assure that the system would perfonn as intenied if called upon with an overall reliability of at least 90%. The last annual test was conducted in October,1996, and all quarterly and monthly tests have been and continue to be conducted as required by the Emergency Plan. The reliability of the PEAS system has been consistently well above 90% since 1990, when the entire system was upgraded, with a reliability of approximately 98% to date for 1997.
With the plant in a pemianently defueled condition, and the plant havi'ig been shut down since December,1996, the risk associated with the operation of the plant has been signincantly reduced, hiost of the design basis accidents described in FS AR Chapter 14 are not possible in the cunent plant condition. The potential source tenu associated with the remaining accidents has been signincantly reduced by the extended length of time that the plant has been shut down.
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With 1) the execlient continued availability of the PEAS system,2) the reduced risk associated with the plant, and 3) the availability of the backup mobile alerting system, the continued conduct of an annual audible test of the PEAS r.iren system is not necessary to provide reasonable assurance that adequate public notification capabilities can be maintained to ensure public health and safety can be protected. The elimination of this test will not reduce tha effec % ness of the Emergency Plan.
The State of Maine concurs with tris plan change.
3.4 EMERGENCY RESPONSE DATA SWTEM (ERDS)
The requirements for an Emergency Response Data System (ERDS) are described in Subpart VI of Appendix E to 10CFR50. The ERDS is also described in Section 7.2.3d of the Maine Yankee Emergency Plan. Paragraph 2 of Appendix E Subpart VI states,in part," Except for Big Rock Point and all nuclear power facilities that are shut down permanently or indefinitely. (emphasis added) onsite hardware shall be provided at each unit by the licensee to interface with the NRC receiving system." Since Mair.e Yankee has been pennanently shut down,it is no longer required to have an ERDS oystem. Since plants which have been pennanently shut down are specifically exempted by Appendix E from the ERDS requirements, the references to ERDS in the Emergency Plan may be deleted without prior NRC approval.
The Emergency Response Data System was intended to provide the NRC with near real time information from the plant computer on a limited data set of select parameters primarily involving i' plant data points. The system was designed to augment the voice transmission over the ergency Notification System (ENS) during complex plant accidents. With the plant in a u
pt nanently defueled condition, the complex plant accidents for which ERDS was primarily intended can not occur. Most of the selected data set are not relevant to the remaining design basis and credible beyond design basis accidents applicable to the defueled plant condition. The remaining accidents are not complex and the ENS is more than adequate for communication of relevant parameters. Therefore, tne ERDS may be climinated without reducing the effectiveness of the Emergency Plan.
3.5 PUllLIC INFORMATION Appendix E to 10CFR50 in section E.IV.D.2 requires in part: " Provisions shall be described for yearly dissemination to the public within the plume exposure EPZ of basic emergency planning information, such as... general infonnation as to the nature and effects of radiation...." Section 8.5 of the Maine Yankee Emergency Plan, describing :he method of providing this educational infomtation to the public has been changed. This information will be provided to local municipal offices. Notice of the availability of educational infomiation will be provided to the public by notices in local newspapers. This method of delivering educational infonnation on radiation is judged to be at least as effective as the previous method. All other required infonnation, such as how the public will be notified, and how to implement protective actions, has already been provided through a telephone book insert, to EPZ residents. The State of Maine has reviewed this plan change and concurs with this approach.
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f 3.6 STATE OF hiAINE NOTIFICATION Sections 5.4,6.2,7.2.1,7.2.2 and Figure 61 of the Maine Yankee Emergency Plan required multiple hotline calls and multiple faxed copies of information in order to notify the State of hiaine of emergency classifications, classification changes, and protective action recommendations aller the state and site emergency centers had been made operational. The method of notifying the state has been streamlined in cooperation with the Maine Emergency Management Agency and the Maine State Police. The notification process now involves notifications from the Oflice of the Emergency Director directly to the state EOC Operations Officer once the state and on site centers have been declared operational. This notification method makes more efficient use of state and site resources without affecting the quality or the quantity ofinfonnation that is being provided. Unnecessary duplication has been climinated, reducing the time needed for office notification and message verification. As this change simplifies and streamlines the notification process, and the process continues to meet the applicable requirements of 10CFR50, it does not reduce the effectiveness of the Emergency Plan.
3.7 MISCEl.LANEOUS CilANGES The Energy Infomiation Center at the Maine Yankee site has been renamed the Career Center No change to the facility has been made which would affect its use during an emergency. Pages 6.16, 6.19 and Figure 71 have been revised to tellect this name change. This change is administrative in nature and does not reduce the effectiveness of the Maine Yankee Emergency Plan.
Figure 5 4 of the Maine Yankee Emergency Plan is being revised to eliminate reference to Offsite Dosimetry Assistants in the EOF. This change is being made to reflect an earlier change to the Maine Yankee Emergency Plan (Reference (d)). This page was inadvertently omitted from the earlier sebmittal to the NRC regarding this change.
Section 6.4 is being modified to change emergency operating procedures (EOP's) to abnormal operating procedures (AOP's). This clauige is necessary since emergency operating procedures are not applicable to the defueled plant condition. This change does not affect the response to an emergency situation, but merely reflects the type of procedure which would be used, therefore this change does not reduce the effectiveness of the Maine Yankee Emergency Plan, 4.0 REGULATORY REQUIREMENTS 4.1 PASS 10CFR50,47(b)(14) n quires in part periodic drills to be conducted to maintain key skills. Appendix E to 10CFR50 in section IV.F.1 requires drills to ensure that employees are familiar,vith their emergency plan duties. Regulations in 10CFR50 do not specifically require drills to be conducted which involve the use of the post accident sampling system.
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4.2 EMERGENCY RESPONSE ORGANIZATION (ERO) STAFFING 10CFR50.47(b)(2) requires, in part, the licensee to maintain adequate stafIlng to provide initial accident response in key functional areas and to inaintain the ability to augment response capabilitics in a timely manner.10CFR50 Appendix E.IV.A requires, in part, that the organization for coping q
with radiological emergencies be described, including dermition of authorities, responsibilities, and duties of individuals assigned to the emergency organization. All critical functions outlined in i
NUREO 0737, Table B 1 guidance, are being fully maintained. Changes are only being made to l
auxilliary/ support type positions not required by Table B 1.
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4.3 ANNUAL AUDIDLE SIREN TEST j
10CFR50.(b)(14) requires that periodic exercises be conducted to evaluate major portions of the emergency response capability. Appendix E to 10CFR50 section IV.F.2 requires that exercises test the emergency notification system. Other tests of the sirens w ll cont nue to be perfomie, providing i
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d reasonable assurance that the sirens would perform as intended if called upon. The regulations do -
not require an annual audible siren test.
i 4.4 EMERGENCY RESPONSE DATA SYSTEM Appendix E to 10CFR50 in section VI describes requirements for the Emergency Response Data System (ERDS). Paragraph VI.2 states in part that the requirements for ERDS do not cpply to facilitics that are shut down pennanently.
4.5 PUBLIC INFORMATION Appendix E to 10CFR50 in section E.IV.D.2 requires in part: " Provisions shall be described for yearly dissemination to the public within the plume exposure EPZ of basic emergency planning infonnation, such as...generalinfonnation as to the nature and effects of radiation...." The revised i
provision for the disse'aination to the public of basic emergency planning information continues to meet this requirement.
4.6 STATE OF MAINE NOTIFICATION Appendix E to 10CFR50 in section E.IV.D.1 states in part:" Administrative and physical means for notifying local, State, and Federal -officials...for public evacuation or other protective measures...shall be described." Appendix E to 10CFR50 in section E.IV.D.3 states in part: "A
- licensee shall have the capability to notify responsible State and local govemmental agencies within
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15 minutes after declaring an emergency." The revised method for notifying the State EOC once the on site and state emergency centers are operational continues to meet these requirements.-
4.7 MISCELLANEOUS CilANGES These changes are administrative in nature. No regulatory requirements are relevant to the changes.
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5.0 CONCLUSION
With Main: Yankee in a permanently defueled plant condition, and the plant having been shut down I
since December 1996, the risk to the public's health and safety associated with the plant has been significantly reduced. It is in the public interest to focus emergency preparedness activities on those which are appropriate in the defueled plant condition. The plan changes described herein are appropriate and do not represent a decrease in the effectiveness of the Emergency Plan in light of the reduced risk associated with the plant in the permanently defueled condition and being decommissioned i
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