HomeMy WebLinkAbout20070133 Ver 1_More Info Received_20071012CLEARWATER ENVIRONMENTAL CONSULTANTS, INC.
October 10, 2007
Mr. Ian McMillan
NC Division of Water Quality
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center
Raleigh, North Carolina 27699
U ~~~U
RE: The Ridge at South Mountain ~~
Laurel Lake and Lake Sandy Plains Monitoring
Rutherford and Polk Counties OC r ~ 2 207
Corps Action ID: 2007328381 ~ENR. ~,A
DWQ Project # 07-0133 ~'~STr~~ry
NCH
Dear Mr. McMillan,
Please reference the "Large Impoundments in Polk/Rutherford Counties" email (Attachment A)
dated July 23, 2007 sent by Mr. Kevin Barnett of the North Carolina Division of Water Quality
(DWQ) in response to the permit application and subsequent communications regarding the
construction of a dam and impoundment at the development known as the Ridge at South
Mountain. At the request of the DWQ, Clearwater Environmental Consultants, Inc. (CEC)
chose two lakes and conducted the required sampling. This sampling provides data that can be
used as a comparison, as well as, offer guidance for construction at the proposed lake within the
Ridge at South Mountain development. Methods, collected data, and an explanation of CEC's
findings will be discussed below.
The Ridge at South Mountain and CEC, with guidance from the DWQ, developed a monitoring
plan to evaluate water quality standards in two impoundments located in the Upper Piedmont
ecoregion of North Carolina. These impoundments are comparable in size (surface area and
watershed) and location; and one lake has a similar cold-water release structure as the lake
proposed at the Ridge at South Mountain.
This submittal also supports previous response to DWQ comments submitted on behalf of the
applicant on April 4, 2007 and May 22, 2007. CEC believes that the applicant is demonstrating a
serious commitment to improving dam design and water quality associated with lakes. The
willingness to institute proposed measures including the installation of a mechanical aeration
system and acold-water release discharge mechanism, implementation of a lake management
plan and the associated operation and maintenance agreements, implementation of the previously
proposed year-long study of water quality parameters, and five years of monitoring should allow
the DWQ to determine that the applicant is going above and beyond to minimize water quality
impacts and mitigate for permanent impacts associated with construction and operation of the
lake.
718 Oakland Street
Hendersonville, North Carolina 28791
Phone: 828-698-9800 Fax: 828-698-9003
www.cwenv.com
Proposed Lake
The Ridge at South Mountain is located northeast of Sunshine in Rutherford County, North
Carolina. The development will be approximately 450 acres and will consist of approximately
225 residential lots and a 30-acre lake. The watershed draining to the lake will be approximately
360 acres. As proposed, the lake will have acold-water release discharge mechanism and
impound an unnamed tributary to Roberson Creek. Roberson Creek is classified as a Class "WS-
V" water by the DWQ.
Study Lakes
Laurel Lake is located in the Bills Creek community of Rutherford County, North Carolina. This
lake is approximately 8 acres with a 335-acre watershed, has acold-water release discharge
mechanism, and impounds an unnamed tributary to Bills Creek. Bills Creek is classified as a
Class "C" water by the DWQ.
Lake Sandy Plains is located in the Sandy Plains community of Polk County, North Carolina.
This lake is approximately 30 acres with a 525-acre watershed, has atop-water release discharge
mechanism, and impounds Collinsville Creek. Collinsville Creek is classified as a Class "C"
water by the DWQ.
A vicinity map, USGS topographic map, and aerial photo for each site has been included for
review (Figures 1-9). The following table summarizes the above information:
Rid es Lake Lake Sand Plains Laurel Lake
Pond Size (acres) 30 30 8
Watershed Size (acres) 360 525 335
Ecore ion Upper Piedmont Upper Piedmont Upper Piedmont
Water Release cold-water top-water cold-water
Impounded Stream UT Roberson Creek Collinsville Creek UT Bills Creek
Stream Classification WS-V C C
Water Quality Sampling and Parameters
Five water quality sampling stations were established at Lake Sandy Plains and Laurel Lake.
The stations were as follows at each lake:
• Station 1 is upstream of the impoundment and samples were taken near the water surface;
• Stations 2 - 4 are evenly spaced across the centerline of the lake and samples were taken
from within 3 inches of the water surface; and
• Station 5 is downstream of the impoundment and samples were taken near the water
surface.
Water temperature, dissolved oxygen (DO), and pH were monitored at each station during
August and early September. Each parameter and monitoring data are indicated in this section;
however, a compiled table including all data for all parameters is enclosed for review
(Attachment B).
Acceptable ranges of water temperature, DO, and pH are defined by the DWQ and are based on
a tributary's surface water classification. The evaluated tributaries and their surface water
classifications can be found in the respective table illustrated under the "Study Lakes" section of
this letter. Surface water classifications present in this study include Class "C" and Class "WS-
V" waters.
Class "C" waters are those waters protected for secondary recreation, fishing, wildlife, fish and
aquatic life propagation and survival, agriculture and other uses suitable for Class "C" waters.
Secondary recreation includes wading, boating, and other uses involving human body contact
with water where such activities take place in an infrequent, unorganized, or incidental manner.
Class "WS-V" waters are those waters that are protected as water supplies, which are generally
upstream and draining to other water supply watersheds, or waters previously used for drinking
water supply purposes or waters used by industry to supply their employees, but not
municipalities or counties, with a raw drinking water supply source. Class "WS-V" waters are
suitable for all Class "C" uses.
The water quality standards for all fresh surface waters, regardless of classification, are the basic
standards applicable to Class "C" waters. Standards associated with Class "C" waters, along
with additional and more stringent standards applicable to other specific freshwater
classifications are specified in NC Administrative Code 15A NCAC 02B.0100, .0200, & .0300,
also known as the "Redbook".
A review of the "Redbook" for standards related to water temperature, DO, and pH for waters
classified as "WS-V", yielded no additional standards or requirements other than those listed for
Class "C" waters.
Water Temperature
Temperature is a critical water quality and environmental parameter because it governs the kinds
and types of aquatic life in the water body, regulates the maximum dissolved oxygen
concentration of the water, and influences the rate of chemical and biological reactions.
Organisms within an ecosystem have preferred temperature regimes that change as a function of
season, organism age or life stage, and environmental factors. With respect to chemical and
biological reactions, the higher the water temperature the higher the rate of chemical and
metabolic reactions (Wilkes University Center for Environmental Quality).
The DWQ indicates that temperature is "not to exceed 2.8 degrees C (5.04 degrees F) above the
natural water temperature and in no case to exceed 29 degrees C (84.2 degrees F) for mountain
and upper piedmont waters".
Temperature sampling results for each of the five locations at Lake Sandy Plains and Laurel
Lake are listed below.
Lake Sandy Plains
Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change
8/8/2007 20.7 no data no data no data 25 4.3
8/21/2007 21.6 32.2 31.1 31.6 25.1 3.5
8/30/2007 19.8 29.6 29.5 29.2 24.4 4.6
9/11/2007 21.1 28.1 28.2 28.1 23.5 2.4
Laurel Lake
Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change
8/8/2007 22.1 no data no data no data 23.3 1.2
8/21/2007 20 29.5 29.1 29.7 21.9 1.9
8/30/2007 23.4 30.1 29.9 29.7 24.5 1.1
9/11/2007 19.7 26.9 26.9 26.6 23.7 4
*temperature measured m "C:
**values in "red" exceed water quality standards
Dissolved Oxygen (DO)
DO is the form of oxygen in water that is freely available to aquatic plants and animals. DO is
vital to fish and other aquatic life and for the prevention of odors. Oxygen is transferred from
the atmosphere into the surface waters at the point of contact where the surface of the water
interfaces with air. Once dissolved in water, oxygen diffuses throughout a water body very
slowly since distribution depends on the movement of aerated water by turbulence and currents,
water flow, and thermal upwelling.
DO would be higher at the lake surface because the lake has a larger surface area and area of
interface when compared to low gradient or slow moving streams. During the summer months, a
process called thermal stratification occurs in many lakes. The water stratifies, or separates, into
two layers: a warm surface layer that is relatively rich in DO and a colder bottom layer. The
oxygen in the lower layer is gradually used up as organic material, which is washed into the lake
when it rains or is discharged from sewage treatment plants, industries, or other sources settles to
the bottom and decays. Because of the temperature difference, the two layers of water do not
mix. As a result, the oxygen in the lower layer is not replaced. By the end of the summer,
oxygen supplies near the bottom can be entirely depleted.
Traditionally, the level of DO has been accepted as the single most important indicator of a water
body's ability to support desirable aquatic life. The amount of oxygen required varies according
to species and the life stage of that species. Usually, DO levels of 5.0 to 6.0 milligram per liter
(mg/1) are required for growth and activity. DO levels below 3.0 mg/1 are stressful to most
aquatic organisms. When levels fall below 2.0 mg/1 for an extended period of time, most fish
will not survive. Oxygen is a particularly sensitive constituent because its availability during
different times of day and different times of year is influenced by temperature, other chemicals
present in the water, and biological processes. Temperature plays a major role in influencing the
amount of DO in water; cold water has the ability to contain more oxygen than warm water
(Texas State University; River Systems Institute).
The DWQ indicates that for non trout waters, DO should not be "less than a daily average of 5.0
mg/1 with a minimum instantaneous value of not less than 4.0 mg/1".
DO sampling results for each of the five locations at Lake Sandy Plains and Laurel Lake are
listed below.
Lake Sandy Plains
Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change
8/8/2007 9.64 no data no data no data 7.5 -2.14
8/21/2007 8.39 9.35 8.6 8.58 7 -1.39
8/30/2007 10.91 6.39 6.4 6.2 5.77 -5.14
9/11/2007 10.67 11.7 11.85 11.2 8.9 -1.77
Laurel Lake
Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change
8/8/2007 8 no data no data no data 6.5 -1.5
8/21/2007 8.3 9.3 9.3 9.45 5.6 -2.7
8/30/2007 5.93 7.41 7.27 7.18 4.89 -1.04
9/11/2007 10.15 11 11.45 11.8 7.3 -2.85
*DO measured in mg/1 using an 1~;x5tik 1)U6UU lltssolved Oxygen ivieter
**values in "red" do not meet water quality standards
Water pH is an indication of the water's acidity measurements on a scale of 1.0 to 14.0, with a
pH of.7.0 considered neutral. A range of pH from 6.5 to 8.2 is optimal for most organisms.
Generally, an aquatic organism's ability to complete a life cycle greatly diminishes as pH
becomes greater than 9.0 or less than 5.0. Rapidly growing algae and submerged aquatic
vegetation remove carbon dioxide from the water during photosynthesis. This can result in
significant increases in pH levels, which in turn can affect aquatic life indirectly by changing
other aspects of the water chemistry. For instance, toxic metals trapped in sediment are released
into the water at lower pH levels, and the level of ammonia that fish can tolerate varies
tremendously within a small range of pH values. Human activities such as accidental spills,
agricultural runoff (pesticides, fertilizers, animal wastes), and sewer overflows may also change
pH (Texas State University; River Systems Institute).
The DWQ indicates that pH "shall be normal for the waters in the area, which generally shall
range between 6.0 and 9.0".
The pH sampling results for each of the five locations at Lake Sandy Plains and Laurel Lake are
listed below.
Lake Sandy Plains
Date Station l Station 2 Station 3 Station 4 Station 5 Overall Change
8/8/2007 7.16 no data no data no data 7.11 -0.05
8/21/2007 8.38 10.5 9.85 9.78 8.32 -0.06
8/30/2007 8.61 9.16 9.08 8.89 8.66 0.05
9/11/2007 8.3 10.02 9.96 9.95 8.24 -0.06
Laurel Lake
Date Station 1 Station 2 Station 3 Station 4 Station 5 Overall Change
8/8/2007 8.33 no data no data no data 7.9 -0.43
8/21/2007 8.26 10.06 9.99 10.13 7.13 -1.13
8/30/2007 8.71 10.7 10.51 10.3 7.78 -0.93
9/11/2007 7.68 9.02 8.96 9.18 7.14 -0.54
*DO measured in mg/1 using an ExStik EC500 pH Meter
**values in "red" do not meet water quality standards
Discussion of Results
Although the data sets in this study are minimal, it is evident from the data collected that
characteristics of water change within a lake setting. How this change effects downstream water
quality depends on many factors including in-lake structures (i.e. cold-water release discharge
mechanism, mechanical aeration), which can be directly deduced by this data, and landscape
orientation.
Temperature
Lake Stations 2 - 4 represent the temperatures present within the body of the lakes. Average
temperature in Lake Sandy Plains for the dates recorded is 29.7°C. Average temperature
upstream of the impoundment for the dates recorded is 20.8°C. When comparing average
upstream temperatures with average in-lake temperatures, this yields a change in temperature of
8.9°C. Average downstream water temperature for the dates recorded is 24.5°C; this is 3.7°C
warmer than average water temperature upstream of the lake. Lake Sandy Plains does not have a
cold-water release discharge mechanism. The water temperature maximum (29°C) listed in the
water quality standards for Class "C" waters is exceeded within the lake boundary. Although
temperatures at Station 1 and Station 5 do not exceed water quality standards, the change of
temperature from Station 1 to Station 5 exceeds the 2.8°C maximum listed for change "above the
natural water temperature". For this study, CEC considered the water temperature measured at
Station 1 to be "natural".
Average temperature in Laurel Lake for the dates recorded is 28.7°C. Average temperature
upstream of the impoundment for the dates recorded is 21.3°C. When comparing average
upstream temperatures with average in-lake temperatures, this yields a change in temperature of
7.4°C. Average downstream water temperature for the dates recorded is 23.4°C; this is 2.1 °C
warmer than the average water temperature upstream of the lake. It is important to note the
"Overall Change" column of the Laurel Lake table. Temperature measurements taken on
September 11, 2007 yield an overall change of 4°C; all other measurements taken yield a change
below 2°C. It is suspected that the data set for September 1 1, 2007 is an outlier. If this data set
is removed from the calculation, average overall change in temperature from upstream to
downstream is 1.4°C, well within the bounds of the water quality standards. Laurel Lake has a
cold-water release discharge mechanism. The water temperature maximum (29°C) listed in the
water quality standards for Class "C" waters is exceeded within the lake boundary; however,
Station 1, Station 5, and the "Overall Change" (not including the September 11, 2007 data set)
meet the water quality standards listed for Class "C" waters.
According to the data collected, lakes increase water temperature (as measured near the surface)
within the lake boundary; however, this should not lead to the conclusion that water discharged
from a lake significantly increases downstream water temperature. The temperature data
collected in this study supports the use of a cold-water release discharge mechanism as a way to
stay within the bounds of the water quality standards for temperature set forth for Class "C"
waters.
Dissolved OxY eg_n (DO)
DO measurements for all dates and all stations, except for the measurement taken at Laurel Lake
at Station 5 on August 30, 2007, exceed water quality standards set forth for Class "C" waters.
In general, DO within 3 inches of the lake surface is greater than the DO upstream of the
impoundment. This trend is evident in all data sets, except for the data set collected at Lake
Sandy Plains on August 30, 2007. Overall change from Station 1 to Station 5, in both lakes,
constitutes a decrease in DO. If measurements from Lake Sandy Plains on August 30, 2007 are
discarded because they do not follow the trend, the average overall decrease in DO for that lake
is 1.76 mg/1 as compared to an average decrease of 2.02 mg/1 in Laurel Lake. Many factors
could explain the difference in these values. One probable cause is the use of the cold-water
release discharge mechanism. The data collected indicates that the use of a cold-water release
discharge mechanism to influence water temperature also influences the level of DO.
Although the difference in DO between the two lakes is small, it appears that decreased DO is a
consequence of the cold-water release discharge mechanism and the desire to discharge cooler
water from the bottom of the lake.
P~
All pH measurements taken at Stations 2 - 4 in both lakes, with the exception of one
measurement at each lake, fall out of the "normal" range indicated by the DWQ. Average pH in
Lake Sandy Plains for the dates recorded is 9.69. Average pH upstream of the impoundment for
the dates recorded is 8.11. When comparing average upstream pH with average in-lake pH, this
yields an increase in pH of 1.58. Average downstream pH for the dates recorded is 8.05; the
average decrease in pH from Station 1 to Station 5 for Lake Sandy Plains is 0.055. Although the
data collected within the lake is out of the "normal" range indicated by DWQ, pH levels
upstream and downstream of the impoundment are similar and well within the stated range.
Average pH in Laurel Lake for the dates recorded is 9.87. Average pH upstream of the
impoundment for the dates recorded is 8.25. When comparing average upstream pH with
average in-lake pH, this yields an increase in pH of 1.62. These measurements are consistent
with those at Lake Sandy Plains; however, the average downstream pH for the dates recorded is
7.49. The average decrease in pH from Station 1 to Station 5 for Laurel Lake is 0.76. The
overall decrease in pH is greater at Laurel Lake. As with DO, it is suspected that one probable
cause is the use of the cold-water release discharge mechanism. Although the data collected
within the lake is out of the "normal" range indicated by DWQ, pH levels upstream and
downstream of the impoundment are well within the stated range.
Many factors affect the pH levels of water. As plants photosynthesize, they remove carbon
dioxide and other nutrients from the water; this process increases pH. In especially low-velocity
or still waters with increased amounts of plant life, such as lakes, an increase in pH can be
expected during the growing season or even during warm, sunny afternoons. Anthropogenic
activities can also significantly effect pH.
Summary and Recommendations
With regards to water temperature, the data collected supports the use of a cold-water release
discharge mechanism as a way to meet water quality standards for Class "C" waters set forth by
the DWQ. CEC supports the proposal to construct acold-water release discharge mechanism on
the intended lake at the Ridge at South Mountain. In general, DO at both study lakes is well
within the bounds of listed water quality standards; however, in both lakes there is a decrease in
DO when comparing Station 1 values with Station 5 values. The overall change in DO indicated
by the measurements leaves room for improvement. If values are troublesome or the DWQ feels
there is a risk of DO values dropping below accepted levels, the Ridge at South Mountain is
prepared to design the outfall to increase DO or install machinery to mechanically aerate the
water discharged from the impoundment. For instance, the DO saturation point of water at 25°C
(the highest outfall temperature recorded, which was from the non-cold-water release lake) is
approximately 8.0 mg/1. The lowest DO reading from an outfall was 4.89 mg/1. Based on the
equation for cascade aeration (H = (R-1)/[((O.ll)ab(1+0.046T)]), only a 9-foot tall cascade
would be required to bring the 4.89 mg/1 up to an ideal DO of 6.0 mg/1 For this particular project,
the outfall temperature should be much cooler yielding a higher DO saturation point, resulting in
DO values exceeding 6.0 mg/1. The pH levels upstream and downstream of the impoundment
are within the general accepted range identified by the DWQ; the pH levels within the lake
exceed the accepted range. CEC recommends that a lake management plan be developed by a
professional lake manager. Specifically identified in this plan should be limitations and
guidelines for land use around the lake and a systematic plan to control aquatic vegetation, which
does not involve the use of chemical herbicides.
With the installation of a cold-water release discharge mechanism and aeration device
(dependent on DWQ guidance), along with the implementation of a lake management plan,
which includes monitoring, CEC feels that the lake proposed at the Ridge at South Mountain will
be consistent with or an improvement over similar lakes in the area. The lake proposed at the
Ridge at South Mountain can be constructed and managed in a way to ensure compliance with
water quality standards set forth by the DWQ for Class "C" waters.
The Ridge at South Mountain requests that the DWQ consider all additional information and
additional measures provided and proposed by the applicant in determining the completeness of
all associated environmental reviews. The applicant is demonstrating a serious commitment and
has gone above and beyond to improve dam designs and water quality associated with lakes.
The Ridge at South Mountain respectfully requests the issuance of the 401 Water Quality
Certification for the specific activities proposed within jurisdictional waters.
Should DWQ have any questions regarding the matters addressed in this letter please do not
hesitate to contact me at (828) 698-9800.
Sincerely,
J/ .,
R. Clement Riddle, P.W. .
Principal
clement riddle
Attachment A
From: Kevin Barnett [Kevin.Barnett@ncmail.net]
Sent: Monday, July 23, 2007 12:15 PM
To: Clement Riddle
Cc: David McHenry; Hair, Sarah E SAW; Amanda Jones; John Dorney; Ian McMillan; Eric Kulz
Subject: Large Impoundments in Polk / Rutherford Counties
:~1
Kevin.Barnett.vcf
(389 B)
Hi Clement:
After much discussion on Friday afternoon and evening, the DWQ will be sending out an
additional information request on these projects again.
In order to ensure that water quality standards are not contraveined, we are asking that
you locate similar sized impoundments in similar sized watersheds in the same eco-region
(upper piedmont) with the same as proposed water release structure. A plan and map for
these facilities will be forwarded to the Regional Office prior to beginning the sampling
protocol.
You are being asked to provide Temp and D.O. monitoring for at least 5 samples over the
month of August (next month) in the stream before the impoundment (near the surface), 3
samples within 3 inches of the surface evenly spaced across the center line of the
impoundment, and one sample in the stream below the impoundment (near the surface).
This data will be collected using standardized methods (EPA methods) using calibrated
equipment.
All collected data and calibration records for said equipment shall be submitted within 15
days of the end of the testing protocol such that the agency can make a determination as
to wether the proposed activity will violate water quality standards, or not.
Thanks,
Kevin
Kevin Barnett - Kevin.Barnett@ncmail.net North Carolina Dept. of Environment and Natural
Resources Asheville Regional Office Division of Water Quality - Water Quality Section 2090
U.S. 70 Highway Swannanoa, NC 28778
Tel: 828-296-4500
Fax: 828-299-7043
1
The Ridge at South Mountain
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O C T 1 2 2007
CLEARWATER wEtuwos AND STORl~WAT6R BRANCH
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Lake Sandy PIaInS Environmental Consultants, [nc.
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Lake Sandy Plains F,nvironmental Consultants, [nc.
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North Carolina Hendersonville, NC 28791
828-698-9800
ATTACHMENT B
Lake Sandy Plains
Date Station 1 (upstream) Station 2 (left) Station 3 (middle) Station 4 (right) Station 5 (downstream) Overall Change (change from Station 1 to
Station 5)
Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H
8/8/2007 20.7 9.64 7.16 no data no data no data 25 7.5 7.11 4.3 -2.14 -0.05
8/21/2007 21.6 8.39 8.38 32.2 9.35 10.5 31.1 8.6 9.85 31.6 8.58 9.78 25.1 7 8.32 3.5 -1.39 -0.06
8/30/2007 19.8 10.91 8.61 29.6 6.39 9.16 29.5 6.4 9.08 29.2 6.2 8.89 24.4 5.77 8.66 4.6 -5.14 0.05
9/11/2007 21.1 10.67 8.3 28.1 11.7 10.02 28.2 11.85 9.96 28.1 11.2 9.95 23.5 8.9 8.24 2.4 -1.77 -0.06
Laurel Lake
Date Station 1 (upstream) Station 2 (left) Station 3 (middle) Station 4 (right) Station 5 (downstream) Overall Change (change from Station 1 to
Station 5)
Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H Tem DO H
8/8/2007 22.1 8 8.33 no data no data no data 23.3 6.5 7.9 1.2 -1.5 -0.43
8/21/2007 20 8.3 8.26 29.5 9.3 10.06 29.1 9.3 9.99 29.7 9.45 10.13 21.9 5.6 7.13 1.9 -2.7 -1.13
8/30/2007 23.4 5.93 8.71 30.1 7.41 10.7 29.9 7.27 10.51 29.7 7.18 10.3 24.5 4.89 7.78 1.1 -1.04 -0.93
9/11 /2007 19.7 10.15 7.68 26.9 11 9.02 26.9 11.45 8.96 26.6 11.8 9.18 23.7 7.3 7. t 4 4 -2.85 -0.54
Le end
Abbreviation Parameter Units
Tem tem erature °C
DO dissolved o en m /I
pH pH no unit
"values in "red" exceed water quality standards for class "C" waters.
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