ML20155G858
From kanterella
| ML20155G858 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/04/1988 |
| From: | Christman J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#488-7222 ALAB-901, LBP-88-24, OL-3, OL-5, NUDOCS 8810180050 | |
| Download: ML20155G858 (24) | |
Similar Documents at Shoreham | |
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Category:BRIEFS
MONTHYEARML20083F1111991-09-25025 September 1991
[Table view]Lilco Brief in Opposition to Petitioner Appeal from LBP-91-1,LBP-91-23 & LBP-91-35.W/Certificate of Svc ML20083B7421991-09-13013 September 1991 Movant-intervenors Brief in Support of Accompanying Notice of Appeal.* Petitioners Urge NRC to Reverse & Remand Memo & Order W/Appropriate Guidance.W/Certificate of Svc CLI-90-08, NRC Staff Response to Joint Petition for Reconsideration of CLI-90-08 by Shoreham-Wading River Central School District & Scientists & Engineers for Secure Energy,Inc.* Motion Should Be Denied.W/Certificate of Svc1990-11-19019 November 1990 NRC Staff Response to Joint Petition for Reconsideration of CLI-90-08 by Shoreham-Wading River Central School District & Scientists & Engineers for Secure Energy,Inc.* Motion Should Be Denied.W/Certificate of Svc ML20196F6991988-12-0101 December 1988 Answers to Intervenors Brief on School Bus Driver Role Conflict & Emergency Broadcast Sys.* Aslab Should Affirm ASLB Decision on Emergency Broadcast Sys & School Bus Driver Role Conflict Issues.Certificate of Svc Encl ML20205N2551988-10-27027 October 1988 Govts Brief in Support of Appeal of 880923 Concluding Initial Decision.* Decision Should Be Reversed.W/Certificate of Svc ML20204F9071988-10-0404 October 1988 NRC Staff Response to Intervenors Motion for Bifurcation of Appeal & Expedition.* Board Should Grasp Nettle on Merits of Whether Intervenors Conduct Warrants Sanction of Dismissal from Proceeding.W/Certificate of Svc ML20155G8581988-10-0404 October 1988 Lilco Answer to Intervenors Brief on Bifurcated Appeal.* Board Had Authority to Dismiss Intervenors from Participating in OL-5 Proceeding & Action Should Be Affirmed.Certificate of Svc Encl ML20151P4971988-08-0101 August 1988 NRC Staff Response to Intervenors Appeal of 880509 Partial Initial Decision on Suitability of Reception Ctrs.* Appeal Has No Merit & LBP-88-13 Should Be Confirmed.Certificate of Svc Encl ML20151N6931988-07-29029 July 1988 Errata.* Lists Corrections to Lilco Suppl to 880615 Brief on Discovery Sanctions in Light of Subsequent Developments. Certificate of Svc Encl ML20151G8471988-07-26026 July 1988 Lilco Suppl to 880615 Brief on Discovery Sanctions in Light of Subsequent Developments.* Board Should Reaffirm Dismissal of Realism/Best Efforts Contentions ML20151G6641988-07-25025 July 1988 Lilco Brief in Opposition to Intervenors Appeal of Board Partial Initial Decision on Suitability of Reception Ctrs.* Appeal Board Should Affirm ASLB Partial Initial Decision LBP-88-13.Supporting Info & Certificate of Svc Encl ML20151A5731988-07-11011 July 1988 Brief of Suffolk County,State of Ny & Town of Southampton Re Disposition of Lilco Appeals of Partial Initial Decisions Re 860213 Exercise.* Lilco Appeals Should Be Decided on Merits or Advisory Opinions.W/Certificate of Svc & Supporting Inf ML20195D3831988-06-20020 June 1988 Suffolk County,State of Ny & Town of Southampton Brief on 3 Appeal of Licensing Board 880509 Partial Initial Decision on Suitability of Reception Ctrs.* Licensing Board Partial Initial Decision Must Be Reversed.Certificate of Svc Encl ML20154E4491988-05-16016 May 1988 Govts Brief in Response to NRC Staff Brief Supporting Lilco Appeal from LBP-88-2.* Board Should Reject NRC CLI-86-13 Argument.W/Certificate of Svc ML20154E4361988-05-0606 May 1988 Lilco Reply to Intervenors & NRC Staff Opposition to Lilco Appeal from LBP-88-2.* Aslab Should Reject Intervenors Arguments in Brief on Appeal from LBP-88-2 & Reverse ASLB Decision in That Opinion.Certificate of Svc Encl ML20151Y4511988-04-28028 April 1988 NRC Staff Response to Lilco Appeal of 880201 Intial Decision on Emergency Plan Exercise.* NRC Supports Util Request That Intial Decision Be Vacated in Areas Where Board Found Fundamental Flaws.Certificate of Svc Encl ML20151P1821988-04-18018 April 1988 Govts Brief in Opposition to Lilco Appeal from LBP-88-2.* Decision of Licensing Board on Contentions Ex 38,39,40,41 & 50 Should Be Affirmed.Certificate of Svc Encl ML20150C6101988-03-14014 March 1988 Lilco Brief on Appeal from 880201 Partial Initial Decision on Emergency Planning Exercise.* Certificate of Svc Encl ML20196F0811988-02-26026 February 1988 Govt Brief in Opposition to Appeal of Lilco from LBP-87-32.* Certificate of Svc Encl ML20195J1031988-01-19019 January 1988 Appeal Brief of Lilco on Contentions Ex 15 & 16.* Requests Reconsideration of 871207 Partial Initial Decision LBP-87-32 Holding That FEMA 860213 Offsite Emergency Preparedness Exercise Not Sufficient for Full Power OL CLI-86-11, NRC Staff Brief on Contention Ex 19.* Lack of FEMA Reasonable Assurance Finding Cannot Be Fundamental Flaw in Plan,As Defined in CLI-86-11.Contention Ex 19 W/O Merit.W/ Certificate of Svc1987-09-11011 September 1987 NRC Staff Brief on Contention Ex 19.* Lack of FEMA Reasonable Assurance Finding Cannot Be Fundamental Flaw in Plan,As Defined in CLI-86-11.Contention Ex 19 W/O Merit.W/ Certificate of Svc ML20214G4991986-11-21021 November 1986 Supplemental Memorandum of Law on Number of People Who May Be Monitored in Radiological Emergency.Certificate of Svc Encl ML20203N9011986-10-16016 October 1986 Reply Brief Requesting Util & NRC 861006 Briefs on Three Issues Addressed in Commission 861019 Order ALAB-832 Re Emergency Planning Be Rejected.Aslb Rulings Should Be Affirmed.W/Certificate of Svc ML20211D7431986-10-16016 October 1986 Answer to Brief of Suffolk County,State of Ny & Town of Southhampton on Three ALAB-832 Issues to Be Reviewed by Commission.Certificate of Svc Encl ML20215D6961986-10-0909 October 1986 Brief on Three Issues Addressed in Commission 860919 Order. Requests That Commission Reverse Aslab Determinations That Contentions 22.B & 22.C Impermissibly Excluded for Litigation.Certificate of Svc Encl ML20211A0141986-10-0909 October 1986 Brief on Issues Under Commission Review Per 860919 Order, Including Plume Emergency Planning Zone Size & Emergency Planning for Hosps.Certificate of Svc Encl ML20210V1791986-10-0909 October 1986 Brief on Three ALAB-832 Issues to Be Reviewed by Commission. ALAB-832 Should Be Affirmed Re Rulings on Admissibility of Contentions 22.B & 22.C & Reversal of Board Ruling on Util Evacuation Plan for Hosp Patients.W/Certificate of Svc ML20141F8481986-01-0606 January 1986 Reply Brief on Appeal of ASLB 850417 Partial Initial Decision Re Emergency Planning ML20141F8631986-01-0606 January 1986 Reply Brief on Appeal of ASLB 850826 Concluding Partial Initial Decision Re Emergency Planning.Certificate of Svc Encl ML20138P6981985-12-23023 December 1985 Brief in Opposition to Suffolk County,State of Ny & Town of Southampton Brief on Appeal of ASLB 850417 Partial Initial Decision on Emergency Planning.Certificate of Svc Encl ML20138P6921985-12-23023 December 1985 Brief Opposing Intervenors Appeal of ASLB 850826 Concluding Partial Initial Decision on Emergency Planning.Litigation Would Be Duplication of Concurrent Review by Commission. Certificate of Svc Encl ML20138J3891985-12-13013 December 1985 Brief in Opposition to Suffolk County & State of Ny 851023 Appeal of ASLB 850417 Partial Initial Decision LBP-85-12 on Emergency Planning.Certificate of Svc Encl ML20138R0841985-12-11011 December 1985 Brief in Opposition to Intervenor Appeal of Nassau Coliseum & Guard Issues Re Emergency Planning Proceeding. Aslab Should Affirm Various Rulings Challenged by Intervenors in 851106 Brief.Certificate of Svc Encl ML20137D6681985-11-21021 November 1985 Brief Supporting Util 851007 Brief in Support of Appeal of ASLB 850826 Partial Initial Decision,Requiring Util Estimate & Plan for Number of Evacuees Who Will Come to Relocation Ctr.W/Certificate of Svc ML20205H3391985-11-12012 November 1985 Brief in Opposition to Util 851007 Brief on Appeal of ASLB 850826 Partial Initial Decision on Emergency Planning & Relocation Ctr Issues.Certificate of Svc Encl ML20198E2691985-11-0606 November 1985 Brief on Appeal of ASLB 850826 Concluding Partial Initial Decision on Emergency Planning.Aslb Erred in Multiple Respects.Certificate of Svc Encl ML20138H2701985-10-23023 October 1985 Suffolk County,State of Ny & Town of Southampton Brief on Appeal from ASLB 850417 Partial Initial Decision on Emergency Planning.Certificate of Svc Encl ML20138A7661985-10-0707 October 1985 Brief Opposing Board 850826 Concluding Partial Initial Decision on Emergency Planning.Requirement to Anticipate Number of People to Be Monitored in Emergency Impossible to Meet & Should Be Reversed.Certificate of Svc Encl ML20132C8801985-07-24024 July 1985 Brief on Legal Authority,Conflict of Interest & State Plan Issues,In Reply to Suffolk County & State of Ny 850711 Brief & NRC 850719 Brief in Response to Util Appeal from ASLB 850417 Decision Re Emergency Planning.W/Certificate of Svc ML20129K1571985-07-19019 July 1985 Brief in Response to Util Appeal from 850417 Partial Initial Decision on Emergency Planning.Legal Authority & State Plan Issues Correctly Resolved.Conflict of Interest Issue Should Be Reversed.Certificate of Svc Encl ML20132F5451985-07-17017 July 1985 Brief in Support of Appeal of ASLB 850614 Partial Initial Decision Holding That Three Emergency Diesel Generators Satisfy Requirements of GDC 17 & 10CFR50,App A.Certificate of Svc Encl ML20129F7571985-07-11011 July 1985 Errata to 850711 Brief of Suffolk County & State of Ny, Consisting of Table of Cases,Statutes,Regulations & Other Authorities ML20129F8121985-07-11011 July 1985 Brief of Suffolk County & State of Ny in Opposition to Licensee Appeal from ASLB 850417 Partial Initial Decision on Emergency Planning.Certificate of Svc Encl ML20117P4521985-06-0303 June 1985 Brief Supporting Applicant Position on Appeal from 850417 Partial Initial Decision Re Emergency Planning.Supporting Documentation Encl ML20112H5501985-01-14014 January 1985 Reply Brief Reaffirming 840905 Order & ASLB 841029 Initial Decision LBP-84-45,recommending Authorization of Low Power Testing Up to 5% Power W/O Completing Qualification of Onsite Diesel Generators.Certificate of Svc Encl ML20108D6531984-12-11011 December 1984 Brief in Support of Appeal of ASLB 841029 Decision Approving Util Exemption Request Re Compliance W/Nrc Regulations Under 10CFR50.12(a) & Request for Low Power License.Certificate of Svc Encl ML20092P7821984-07-0606 July 1984 Brief in Support of ASLB 840625 Order Denying Suffolk County & State of Ny Motion to Disqualify Judges Miller,Bright & Johnson.Certificate of Svc Encl ML20087C6411984-03-0202 March 1984 Reply Brief Re Contentions 7B on Classification & Sys Interactions & 12-15 on Qa/Qc.Certificate of Svc Encl ML20087L8521983-12-23023 December 1983 Util Safety Classification Group Brief Amicus Curiae Objecting to ASLB Distinction Between Regulatory Terms Important to Safety & safety-related ML20076G8971983-08-24024 August 1983 Response Supporting Citizens for Orderly Energy Policy,Inc Appeal from ASLB 830728 Memorandum & Order LBP-82-42 Denying Citizens Petition to Intervene.Relevant Factors Offset Citizens Untimeliness.Certificate of Svc Encl 1991-09-25 Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS MONTHYEARML20093G4541995-10-18018 October 1995
[Table view]Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc 1995-10-18 |
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