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HomeMy WebLinkAboutNCS000476_Canton MS4 AUDIT REPORT_20201201MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000476 Canton, NORTH CAROLINA 58 Park Street Canton, NC 28716 Audit Date: November 19, 2020 Report Date: December 1, 2020 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 (This page intentionally left blank) Audit Date: November 19, 2020 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 TABLE OF CONTENTS AuditDetails..................................................................................................................................................1 PermitteeInformation..................................................................................................................................2 SupportingDocuments.................................................................................................................................3 Program Implementation, Documentation & Assessment...........................................................................4 Public Education and Outreach.....................................................................................................................7 Public Involvement and Participation...........................................................................................................8 Illicit Discharge Detection and Elimination(IDDE)........................................................................................9 Pollution Prevention and Good Housekeeping for Municipal Operations.................................................11 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................13 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................14 Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................15 Appendix B: Photograph Log DISCLAIMER This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This audit report does not include a review of all program components, and program deficiencies in addition to those noted may be present. The permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. Audit Date: November 19, 2020 ii MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 This page intentionally left blank Audit Date: November 19, 2020 iii MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Audit Details Audit ID Number: Audit Date(s): NCS000476 Canton MS4 Audit 20201119 November 19, 2020 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment ® Public Education & Outreach ® Public Involvement & Participation ® Illicit Discharge Detection & Elimination ❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program ❑ Post -Construction Site Runoff Controls ® Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads (TMDLs) Field Site Visits: ® Municipal Facilities. Number visited: 2 M MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: Number visited: Choose an item. ❑ Other: Number visited: Choose an item. Inspector(s) Conducting Audit Name. Title Organization Isaiah Reed, Environmental Specialist NCDEQ Audit Report Auth Date::: Signatur Audit Date(s): November 19, 2020 Page 1 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Permittee Information MS4 Permittee Name: Town of Canton Permit Effective Date: February 21 2017 Permit Expiration Date: February 19, 2022 City, State, ZIP: Canton, North Carolina 28787 Date of Last MS4 Inspection/Audit: None Co-permittee(s), if applicable: N/A Permit Owner of Record: Seth Hendler-Voss, Town Manager (Not correct) Primary MS4 Representatives Participating in Audit Name, Title Orxanization Johnny Gibson, Street Dept. Supervisor Town of Canton Richard Hodge, Water and Sewer Superintendent Town of Canton Jason Burrell, Town Manager Town of Canton Nick Scheuer (Remote) Town of Canton MS4 Receiving Waters Waterbodv Classification Impairments Pigeon River C None known Hominy Creek C None known Beaverdam Creek C None known Mingus Branch C None known Audit Date(s): November 19, 2020 Page 2 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Supporting Documents Item Number Document Title When Provided (Prior to/During/After) 1 Catch basin cleaning inventory. Prior to 2 Common stormwater handout During 3 Stormwater Ordinance Prior to 4 Outfall Inventory Map Prior to 5 Stormwater Management SOP Prior to Audit Date(s): November 19, 2020 Page 3 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Program Implementation, Documentation & Assessment Staff Interviewed: Jason Burrell, Town Manager (Name, Title, Role) Richard Hodge, Water and Sewer Superintendent Nick Scheuer (Remote) Johnny Gibson, Street Dept. Supervisor Permit Citation Program Requirement Status supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. Yes Funding The Stormwater Plan identifies a specific position(s) responsible for the overall coordination, implementation, and revision to the Plan. No Responsibilities for all components of the Stormwater Plan are documented and position(s) assignments provided. No --- The permittee is current on payment of invoiced administering and compliance monitoring fees (see stormwater e-payments on DEMLR MS4 web page). yes BIMS While a SWMP Draft has been created, No SWMP has been submitted and maintained. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan components at least annually. No --- Implementation and Evaluation If yes, the permittee used the results of the evaluation to modify the program Not components as necessary to accomplish the intent of the Stormwater Program. Applicable Did the permitted MS4 discharges cause or contribute to non -attainment of an Not applicable water quality standard? Reviewed If yes, did the permittee expand or better tailor its BMPs accordingly to address Not the non -attainment? Applicable --- No annual evaluation has been documented. No assessment has been done of water quality standards. II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. No --- Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. No --- No SWMP has been maintained throughout the permit period. II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the of the Stormwater Division and the public online. No --- Plan The online materials included ordinances, or other regulatory mechanisms, or a list identifying the ordinances, or other regulatory mechanisms, providing the legal Partial --- authority necessary to implement and enforce the requirements of the permit. Can ton nc. tom/s torm wate r Audit Date(s): November 19, 2020 Page 4 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Program Implementation, Documentation & Assessment II.A.3 & II.A.5 Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? Not Modifications Applicable If yes, did the permittee complete the modifications in accordance with the Not established deadline? Applicable No SWMP has been submitted. II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes --- If yes, is there a written agreement in place? No --- Haywood County implements an erosion and sediment control program. II.A.7 The permittee maintained written procedures for implementing the six minimum Written control measures. No --- Procedures Written procedures identified specific action steps, schedules, resources and responsibilities for implementing the six minimum measures. No In the process of creating these written procedures. IIIA The permittee maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, partial 1 Documentation mplementation of BMPs, enforcement actions etc., on file for a period of five years. Some program components have been documented. 111.13 The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit (See Section 111.B. for the annual reporting Yes --- Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the scheduled date of the first annual report submittal. Yes The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Plan, including, but not limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole. This will include information on development and implementation Not of each major component of the Stormwater Plan for the past year and Reviewed schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to the Stormwater Plan. This will include descriptions and supporting information for Not the proposed changes and how these changes will impact the Stormwater Reviewed --- Plan (results, effectiveness, implementation schedule, etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Not Plan. Reviewed 4. A summary of data accumulated as part of the Stormwater Plan throughout the year along with an assessment of what the data indicates in light of the Not Stormwater Plan. Reviewed Audit Date(s): November 19, 2020 Page 5 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Program Implementation, Documentation & Assessment 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement7Reiewed actions. Annual reports are available through BIMS. IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable, specific Not quantities achieved and summaries of enforcement actions. Reviewed 2. A description of the effectiveness of each program component. Not Reviewed 3. Planned activities and changes for the next reporting period, for each Not program component or activity. Reviewed 4. FISGaI analysis. NotReviewed Annual reports are available through BIMS. Audit Date(s): November 19, 2020 Page 6 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Public Education and Outreach Staff Interviewed: Jason Burrell, Town Manager (Name, Title, Role) Richard Hodge, Water and Sewer Superintendent Nick Scheuer (Remote) Johnny Gibson, Street Dept. Supervisor Permit Citation Program Requirement Status Supporting Doc No. 11.82.a Goals and The permittee defined goals and objectives of the Local Public Education and Objectives No --- Outreach Program based on community wide issues. Cantonnc.com/Stormwater 11.6.2.b The permittee maintained a description of the target pollutants and/or stressors and Target Pollutants likely sources. No Contonnc.com/Stormwater II.B2.c The permittee identified, assessed annually and updated the description of the target Target Audiences audiences likely to have significant storm water impacts and why they were selected. No An annual assessment of target audiences has not been conducted. II.8.2.d Residential The permittee described issues, such as pollutants, the likely sources of those and Industrial, pollutants, potential impacts, and the physical attributes of stormwater runoff in Partial 2 Commercial Issues their education/outreach program. Common SW handout, 11.8.2.e Informational The permittee promoted and maintained an Internet web site designed to convey the Web Site program's message. Yes --- Contonnc.com/Stormwater 11.B.2.f Public Education The permittee distributed stormwater educational material to a P appropriate target Materials groups. Partial 2 Schools and available in the Lobby. 11.6.2.E The permittee promoted and maintained a stormwater hotline/helpline for the Hotline/Help Line purpose of public education and outreach. No --- No hotline has been maintained for Public Outreach. II.B.2.h The permittee's outreach program, including those elements implemented locally or Public Education through a cooperative agreement, included a combination of approaches designed to No --- and Outreach reach the target audiences. Program For each media, event or activity, including those elements implemented locally or through a cooperative agreement the permittee estimated and recorded the extent No --- of exposure. Audit Date(s): November 19, 2020 Page 7 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Public Involvement and Participation Staff Interviewed: Jason Burrell, Town Manager (Name, Title, Role) Richard Hodge, Water and Sewer Superintendent Nick Scheuer (Remote) Johnny Gibson, Street Dept. Supervisor Permit Citation Program Requirement Status Supporting Doc No. II.C.2.a Volunteer Community The permittee included and promoted volunteer opportunities designed to promote Involvement No ongoing citizen participation. Program Public involvement as not been documented. II.C.2.b Mechanism for The permittee provided and promoted a mechanism for public involvement that Public provides for input on stormwater issues and the stormwater program. Yes T- Involvement Haywoodwaterways.org 4Contonnc.com/stormwater II.C2.c The permittee promoted and maintained a hotline/helpline for the purpose of public Hotline/Help Line involvement and participation. No No hotline has been maintained for Public Involvement. Audit Date(s): November 19, 2020 Page 8 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Jason Burrell, Town Manager (Name, Title, Richard Hodge, Water and Sewer Superintendent Role) Nick Scheuer (Remote) Johnny Gibson, Street Dept. Supervisor Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. No --- If yes, the written program includes provisions for program assessment and Not evaluation and integrating program. Applicable No written IDDE Program has been created and maintained. The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. Yes 3 Legal Authorities If yes, the ordinance applies throughout the corporate limits of the permittee. [Permit Part I.D] Yes 3 II.D.2.c Storm Sewer The permittee maintained a current map showing major outfalls and receiving System Map streams. No 4 II.D.2.d Dry Weather Flow The permittee maintained a program for conducting dry weather flow field Program observations in accordance with written procedures. No A map was put together in 2007 but has not been maintained. NO Dry weather flow field observation program has been established. ILD.2.e Investigation The permittee maintained written procedures for conducting investigations of Procedures identified illicit discharges. No No specific written IDDE program has been maintained. II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the Track and following: Document Investigations 1. The date(s) the illicit discharge was observed Not Reviewed 2. The results of the investigation Not Reviewed 3. Any follow-up of the investigation Not ... Reviewed 4. The date the investigation was closed Not Reviewed Southern Software is used for tracking. Audit Date(s): November 19, 2020 Page 9 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Illicit Discharge Detection and Elimination (IDDE) II.13.2.e Employee The permittee implemented and documented a training program for appropriate Training municipal staff who, as part of their normal job responsibilities, may come into No --- contact with or otherwise observe an illicit discharge or illicit connection. No training had been documented. II.D.2.1h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. Yes 2 The permittee informed businesses of hazards associated with illegal discharges and improper disposal of waste. No --- The permittee informed the general public of hazards associated with illegal discharges and improper disposal of waste. Yes 2 No effort to educate local business owners of the required hazards has been documented. II.D.2.i The permittee promoted, publicized, and facilitated a reporting mechanism for the Public Reporting public to report illicit discharges. Yes Website Mechanism The permittee promoted, publicized, and facilitated a reporting mechanism for staff to report illicit discharges. No --- The permittee established and implemented response procedures for citizen requests/reports. Yes S Procedures are outlined in the SOP. II.D.2.1 The permittee implemented a mechanism to track the issuance of notices of violation Not Southern Enforcement and enforcement actions administered by the permittee. Reviewed Software If yes, the mechanism includes the ability to identify chronic violators for Not initiation of actions to reduce noncompliance. Reviewed No notice of violation has been documented to track. Audit Date(s): November 19, 2020 Page 10 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Jason Burrell, Town Manager (Name, Title, Role) Richard Hodge, Water and Sewer Superintendent Nick Scheuer (Remote) Johnny Gibson, Street Dept. Supervisor Permit Citation Program Requirement Status supporting Doc No. II.G.2.a The permittee maintained a current inventory of facilities and operations owned Facility Inventory and operated by the permittee with the potential for generating polluted No --- stormwater runoff. No list specifying facilities with potential for generating polluted SW runoff. II.G.2.b The permittee maintained and implemented an 0&M program for municipally Operation and owned and operated facilities with the potential for generating polluted No --- Maintenance (O&M) stormwater runoff. for Facilities If yes, the O&M program specifies the frequency of inspections. Not Applicable If yes, the 0&M program specifies the frequency of routine maintenance Not requirements. Applicable If yes, the permittee evaluated the 0&M program annually and updated it as Not necessary. applicable '-- To be created. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. Yes 5 Procedures Spill response procedures are documented in the SOP. II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater Roads, and Public runoff from municipally -owned streets, roads, and public parking lots within its No --- Parking Lots corporate limits annually. Maintenance If yes, the permittee evaluated the effectiveness of existing and new BMPs Not based on cost and the estimated quantity of pollutants removed. Applicable No annual evaluation has been documented. II 0&M for Catch f The permittee maintained and implemented an 0&M program for the stormwater Basins and sewer system including catch basins and conveyance systems that it owns and Partial --- Conveyance Systems maintains. An O&M plan was not available at the time of the inspection, but an inventory has been maintained. II.G.2.e The permittee maintained a current inventory of municipally -owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Not Stormwater Controls construction ordinance. Applicable No permitted SCMs in the municipality. Audit Date(s): November 19, 2020 Page 11 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.h The permittee maintained and implemented an C&M program for municipally - O&M for Structural owned or maintained structural stormwater controls installed for compliance with No --- Stormwater Controls the permittee's post -construction ordinance. If yes, then: The 0&M program specified the frequency of inspections and routine Not maintenance requirements. Applicable The permittee documented inspections of all municipally -owned or maintained Not structural stormwater controls. Applicable The permittee inspected all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable The permittee maintained all municipally -owned or maintained structural Not stormwater controls in accordance with the schedule developed by permittee. Applicable The permittee documented maintenance of all municipally -owned or Not maintained structural stormwater controls. Applicable No O&M Plan has been maintained. II.G.23 The permittee ensured municipal employees are properly trained in pesticide, Pesticide, Herbicide herbicide and fertilizer application management. Yes and Fertilizer Application The permittee ensured contractors are properly trained in pesticide, herbicide and Management fertilizer management. Yes --- The permittee ensured all permits, certifications, and other measures for applicators are followed. Yes II.G.2.j The permittee implemented an employee trainin P pg program for employees involved Staff Training in implementing pollution prevention and good housekeeping practices. No --- No training has been documented for Pollution Prevention and Good Housekeeping. II.G.2.1c The permittee described and implemented measures that prevent or minimize Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment Yes s Equipment Cleaning cleaning. Audit Date(s): November 19, 2020 Page 12 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Water Treatment Plant Date and Time of Site Visit: November 19, 2020 12:45 PM Facility Address: England Road Facility Type (Vehicle Maintenance, Landscaping, etc.): Water Treatment Name of MS4 inspector(s) evaluated: Jason Burrell Most Recent MS4 Inspection (List date and name of inspector): None Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Richard Hedge Water and Sewer Superintendent Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No What type of stormwater training do facility employees receive? How often? None Documented Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? None Documented Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? No Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? No Does the MS4 inspector's process include taking photos? No Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? No Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? No Did the M54 inspector miss any obvious areas of concern? If so, explain: Yes. Damages to the secondary containment at the Caustic storage area have not been addressed. Does the M54 inspector's process include presenting the inspection findings to the facility contact? No Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Yes. Repair of secondary containment. Timeline for repair not discussed. Audit Date(s): November 19, 2020 Page 13 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Site Visit Evaluation: Municipal Facility No. 2 Facility Name: Public Works Date and Time of Site Visit: November 19, 20201:35 PM Facility Address: Summer Street Facility Type (Vehicle Maintenance, Landscaping, etc.): Public Works Name of MS4 inspector(s) evaluated: Jason Burrell Most Recent MS4 Inspection (Date and Entity): None Documented Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit: Name Title Johnny Gibson Street Department Supervisor Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific? No What type of stormwater training do facility employees receive? How often? None Documented. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? None Documented. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? No. Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping? No. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? No. Does the MS4 inspector's process include taking photos? No. Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)? No. Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? No. Did the M54 inspector miss any obvious areas of concern? If so, explain: No major issues, however storage of white goods was discussed as a potential source of pollutants. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? No. Inspection Results Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)? Housekeeping was discussed as a potential area for improvement. Audit Date(s): November 19, 2020 Page 14 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: Not numbered November 19, 20201 PM Outfall Location: Outfall Description (Pipe Material/Diameter, Culvert, etc.): Holtzclaw Street CMP 181, Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate, Not reviewed Sheen, Odor, Floatables/Debris, etc.): No flow is present Most Recent Outfall Inspection/Screening (Date): None Days Since Last Rainfall: Inches: Not evaluated N/A Name of M541nspector(s) evaluated: Jason Burrell Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive? How often? None documented. Did the M54 inspector appear knowledgeable about illicit discharge indicators and investigations? No. Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? No. Does the inspector's process include taking photos? No. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they? No. Inspection Results Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)? None. Will a follow-up outfall inspection be conducted? If so, for what reason? Yes. Routine. Notes/Comments/RecoM m end ations Audit Date(s): November 19, 2020 Page 15 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 APPENDIX B: PHOTOGRAPH LOG Cracked secondary containment at Water Treatment Facility. Audit Date(s): November 19, 2020 Page 16 of 18 MS4 Permit Audit Report Canton, NC: NPDES Permit No. NCS000476 A.-. v+ s 1 . `- ihilfl99��o s r. White goods storage area at the Public Works facility. 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