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3 hours ago, et1883 said:

From some of the charts it seems that ventilation, power back up, alarms are the primary differences between F-1 and H3

Of course this is all up to your AHJ.  Just in case your want to take a look at all the things you need to consider, the link provided might bring a few additional things to mind. 

https://www.auroragov.org/UserFiles/Servers/Server_1881137/File/Business Services/Building/Building and Fire/Fire - Life Safety/013111/010440.pdf    

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My tanks are 250, 550 and 750 gallons and they are stackable.  They are rated for spirit storage and are stainless steel.  My pricing is much better than Skolniks per gallon and my tanks will store mo

Plastic totes are only approved for transport but you can walk into most any distillery and see them stacked floor to ceiling.  If a fire were to break out they melt and help to fuel the fire.  There

Hi Nabtastic, For what it's worth, we recently moved locations (new fire and building approvals), and we had to modify 13 stainless steel single wall tanks with pressure release vents and sealed li

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20 hours ago, dhdunbar said:

About building and fire codes I know nothing, but for those who want to know the source of Southhighlander' s  contention,  §19.192 discusses where you must use TTB approved locks:

  • Subsection (e) Approved locks. Locks meeting the specifications prescribed in paragraph (f) of this section must be used to secure:  (1) Outdoor tanks used to store spirits, OR an enclosure around such tanks." The emphasis is mine, but "or" is disjunctive.  It is one or the other and  I'd advise both as a way of securing your assets, even if TTB settles for just one. 

TTB hasn't been very strict about enforcing tank requirements for inside tanks. Compare what you see to what it requires below to verify that comment.  I suspect that it would be more stringent with outside tanks, so visit  §19.182, which requires, in pertinent part,  that all tanks be:

  • Equipped with accurate means for measuring their contents. If the means for measurement is not a permanent fixture on the tank, the proprietor must equip the tank with a fixed device for measuring the contents. However, tanks having a capacity of less than 101 gallons are not required to have permanent gauge devices;
  • Accurately calibrated if used for any of the gauges described in this part [for example, an inventory :-)].  Further, if tanks or their gauging devices are moved in any manner subsequent to original calibration, the tanks shall not be used until recalibrated;
  • Accessible through walkways, landings, and stairs that permit access to all parts of the tank [TTB must be able to reach the top safely];
  • Equipped or situated so that they may be locked or secured [this includes  manholes as well as valves]; and
  • Constructed to prevent access to the spirits or wines through vents, flame arresters or other safety devices.  

Generally, there are no taxes due on spirits that are lost, but hen it appears that a theft occurred, the burden of proof will be on the proprietor or other person liable for the tax to establish to the satisfaction of the appropriate TTB officer that the theft did not result from connivance, collusion, fraud, or negligence on the part of the proprietor, owner, consignor, consignee, bailee, or carrier, or any employee or agent of any of them."  That one cannot prove a negative is obvious, so how do you prove that no employee was involved?  In practice, some  of the burden will fall on TTB to prove that an employee was involved.  But TTB is likely to determine that theft from a tank  that is not constructed as required by §19.182 is the result of your negligence.  Even if TTB accepts an offer-in-compromise of dimes on the dollar, as it has done in at least one case, because  tanks hold a lot of spirits, the amount you end up paying can be significant.  So, if you use an outside tank, make sure the tank complies with the rules.
 

dhdunbar is correct.  You of course will need to secure your tank with TTB approved padlocks and you will need a tank with a measuring device and that is no problem for us to supply.  As far as I know there has not been a theft from an outside storage tank in many years (Jack Daniels had losses from a storage tank in Saint Louis MO over 70 years ago).  In the last couple of decades there have been thefts of bottles (Pappy Van Winkles) and from barrels in rack houses, but none from storage tanks that I can find records of.  If you are in the city or any area where you think that your tank might be broken into, I suggest the tank be padlocked with a metal cage around it with a padlock on the cage door.  The padlocks and cage will cost you a tiny percentage of what firewalls and sprinklers cost.  Just follow those TTB rules.

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There was one case in which a DSP left a lock off a railroad tank car that was sitting in the DSP's yard.  The tax value of the spirits that disappeared into the night was over $600,000 and TTB settled for a $60,000 OIC.  That was probably about five years ago.  But generally, there has not been a problem with thefts from outside tanks.  I know of one distillery in Oregon that has used them for 50 years without a single incident that I know of.  That said, one insures against the possibility to ensure that if the improbable happens one has a way of dealing with it.  Southernhighlander suggests hoods.  ATF requires hoods over padlocks oin explosive magazines.  Doing that would show you went the extra mile.  It is a good idea.

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If I'm reading this all correctly, the tanks themselves don't need to be locked when stored outdoors, provided there is sufficient security to prevent unwanted access.  I.e. a fence/border wall with appropriately beefy locks would suffice?   How would you convey the spirits back indoors for processing?  I'm assuming you can't have a tank outside with a locked valve and piping to an indoor bottling room, for example?  Also, where does someone find locked (with a key) valves?  I don't think I've ever came across them.

Thanks for the lively discussion on codes.  Love this industry :)

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You are correct.  Under the provisions of §19.192 the tanks themselves do not need to be locked, if they are within an enclosure and the enclosure is locked.  That is as definitive as TTB gets. 

"Enclosure" is not defined.  it has the common meaning "an area surrounded by a fence or other structure in order to be kept separate from other areas."  One supposes the adequacy depends on the purpose.  In the case of an enclosure around outside tanks, it is surely more than a one foot high buffer and less than 25 foot high fence, but I don't know of any guidelines about where in between the extremes, Goldilocks style,  t too little and too much become just right.    You must describe it on your application to register the DSP  - or an amendment to an existing registration - and in theory, at least, TTB will say thumbs up or thumbs down by its approval or denial.

But locked or not, all tanks must be equipped for locking. would leave an outside tank unlocked if were within a locked enclosure.  No, unless I were sure that the fence was truly adequate to secure the spirits.  But that is a matter of my caution, not an imposed requirement.  

I know of nothing that precludes a permanent pipe between the outdoor tank and an inside tank.  They exist.  Again, I know of no rules that say how the pipeline would need to be constructed, but I would assume continuous piping.  In one place, in the days when TTB provided better explanations than it does now in its online instructions, it gave the following example of how to explain the "arrangement of buildings," "Building A is located on the bonded premises directly west of Building B. A bonded bulk tank farm consisting of 10 tanks is located 150 feet to the west of Building A. The tanks are arranged in two rows of 5. Each tank is connected by pipeline to the bottling plant . My emphasis.  

The valves don't lock with a key :-); they are equipped so that they can be locked with a padlock of the sort required by §19.192(f).  Local locksmiths should be able to provide those padlocks  and if not, I'm sure people here on the forum can tell you where you can find them online.  

 

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23 hours ago, nabtastic said:

If I'm reading this all correctly, the tanks themselves don't need to be locked when stored outdoors, provided there is sufficient security to prevent unwanted access.  I.e. a fence/border wall with appropriately beefy locks would suffice?   How would you convey the spirits back indoors for processing?  I'm assuming you can't have a tank outside with a locked valve and piping to an indoor bottling room, for example?  Also, where does someone find locked (with a key) valves?  I don't think I've ever came across them.

Thanks for the lively discussion on codes.  Love this industry :)

nabtastic,

 

This is really simple. You can use pad lockable valves like dhdunbar suggests or better yet, just plumb to the outside storage tanks and have the valves and pumps inside the building.  I really like nice simple common sense solutions, that save huge amounts of money.

 

 

If you really want to have an enclosure around the tanks I suggest a metal cage on all 4 sides with a pad locked door.  i would also still lock the tank or tanks like dhdunbar suggests

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6 hours ago, Southernhighlander said:

This is really simple.

I'm no expert but the 2015 - International Fire Code Chapter 57 does not make it sound that simple.  Before you rush out and buy your tank and TTB approved locks it might be prudent to have your AHJ do a code review on this document.  They would probably need to do a code review on the tank construction being in compliance with NFPA 30 as well.

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It's simple to us.  These are the same fire and safety code requirements that we have been dealing with for years, for our stills, ethanol storage tanks, electrical heating systems, electric agitators, pneumatic explosion proof transfer pumps,  that we currently have in over 300 distilleries in the US and Canada.   

I am the CEO of another business that sells laboratory equipment including rotary evaporators, short path stills, falling film evaporators, thin film rotary evaporators. BHO extractors, cracking columns, ethanol extractors, chromatography equipment that utilizes flammable solvents as well as molecular sieving equipment for processes using flammable solvents. 

We have supplied equipment to some very large scale processing facilities, such as the Bi Nutraceuticals processing facility on Long Island, which extracts oils from hundreds of different plant materials using ethanol extraction.  We are currently working on proposals for some of the largest Hemp to CBD processing facilities in the US.

Whether your UL 142 listed ethanol storage tank is indoors or outdoors you still have to abide by the fire safety codes, however being outdoors does not require sprinklers or fire walls around the tanks, which saves you huge amounts of money.  If anyone needs UL 142 outdoor ethanol storage tanks, explosion proof pumps, valves, vents, safety valves vacuum relief valves etc, that meet the International fire code requirements, we are here for you.  If you purchase equipment from us we will give you guidance concerning hazardous environment classifications, as they pertain to the equipment that we sell you, free of charge.  

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Respectfully disagree.  The UL142 tanks are not the issue, they are built to NFPA 30 specs.  But, the placement of the tanks are up to the AHJ and from what I can see many States and cities seem to have their own take on Chapter 57.  A code review prior to purchase just make sense.

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1 hour ago, Thatch said:

Respectfully disagree.  The UL142 tanks are not the issue, they are built to NFPA 30 specs.  But, the placement of the tanks are up to the AHJ and from what I can see many States and cities seem to have their own take on Chapter 57.  A code review prior to purchase just make sense.

A code review is always a good idea.  I never disagreed with that in any way. 

If you are adding an outside storage tank and plumbing to and from it, you will need to choose the placement very carefully.

However the placement of the the tanks is not up to the AHJ.  The placement of the tanks is up to the person or business entity that has rightful control of the tank and has rightful control of the property upon which the tank is going to sit. As long as the tank meets all of the requirements and all requirements are met concerning any hazardous environments and all permits are in order and everything passes inspection, you can put the tank wherever you like.  I have 3 outdoor storage tanks here that contain flammable/explosive liquids and I decided where to put them all. Two of them are plumbed into buildings.  I had zero issues getting it done.  Each was a simple inexpensive solution.  Neither OSHA nor my insurance company have given me any grief about them

What I said from my original statement and onward is  that exterior tanks for storage of flammable/explosive liquids typically involve a great deal less hassle than indoor tanks containing the same thing.   After all, there are tens of thousands of outdoor tanks in most cities and large suburbs, some of them holding thousands of gallons of flammable and explosive liquids. 

Using outside tanks is generally a much simpler and more common sense solution, compared to having to install a sprinkler system and walls that must with stand explosion and high temps for extended periods.  It's a fact and I don't understand why anyone would argue the point. 

We make things simpler for our customers by helping them meet whatever requirements exist concerning the equipment that we sell them.  .  We have a great deal of experience with it.

Believe it or not, it's stills that get the most attention from AHJs.  Stills seem to scare them a great deal more than outside storage tanks or any other piece of equipment around a distillery.  Outside storage tanks have no electrical components.  Our steam stills have electric agitators which must meet hazardous environment requirements.  Our baine marie stills have agitators and electrical heating systems that must meet hazardous environment requirements and they do.

All of the codes that we have ran into for explosive liquids and vapors are pretty uniform in the US and Canada, individual Inspectors can have different interpretations but those interpretations rarely very to any great degree.

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The OP was trying to avoid H classification.  You proposed this as a simple solution to stay with F-1.  I will stick to my original post which said don't buy anything before you do a code review.  

14 hours ago, Southernhighlander said:

However the placement of the the tanks is not up to the AHJ. 

There are setbacks from both property lines and buildings called out in Chapter 57

You said this was simple.  Perhaps in Missouri it is but if you are in California the piping that was discussed might have to be earthquake proof depending on jurisdictions. 

NFPA 30 will certainly come into play if you are having a tank built for you.  Your AHJ might even require a UL 2085 tank rather than the UL142

14 hours ago, Southernhighlander said:

Neither OSHA nor my insurance company have given me any grief about them

I will also add that you need to consult with your insurance company before adding a tank.  Some insurance companies will require a concrete base rather than the typical metal.  Their requirements with regard to setbacks may be more stringent than the AHJ's

The link is to a document from a tank manufacturer in Oregon that may be helpful to anyone considering purchasing an outdoor tank.

http://www.eagletanks.com/guide/Fuel Tank Buying Guide.pdf

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I'll leave my area of expertise and express some opinions here.  Call them an observation about life in general. 

There are situations that are complicated.  I use the word to denote things that are hard to understand, but which, if you understand them, you can confidently predict the outcome.  Then there situations that are complex.  I use that term to denote situations in which, even if you know the rules, you cannot predict the outcome.  For example, the rules of law that apply to a situation may be complicated, but the judge can provide the jury with instructions about how the rules apply to the case the jury is weighing.  What the jury will decide, when applying, or ignoring, those rules, is unpredictable. It is complex in the way I use the word.   TTB labeling rules for whiskey are the same.  You can  understand correctly what they say - you may wonder at how they came to say what they say - but you cannot predict what TTB will do when you submit an application for a certificate of label approval.  The rules are complixated, the situation is complex.

So too, it seems, is how the person who is deemed to be the authority having jurisdiction is going to apply the development and fire codes.  The complexity is amplified when the agency decides it has given a wrong answer to a preliminary question.  Not even asking in advance can give absolute assurance.  So we arrive at Murphy's law, to which I might propose the corollary, "There is no rule that someone will not misinterpret."  To which I add,  "There is no rule that someone will not ignore," and "In the absence of a rule, there is someone who will invent one." Uncertainty has many roots..

In the discussion of outside tanks, I seesee two themes.  One comes from the general experience that the rules that may apply to outside tanks have not caused problems.  There are three possible reasons for this.  One is that persons generally comply with the rules, so it is reasonable that there have been no problems. The second is that  the code books are so thick that the authority with jurisdiction doesn't know what rules to apply.  The third is that the agency doesn't care what the rule book says.  Any of those situations may exist.  I'm also sure that we could, collectively, site examples of each.

Here is my reading of this discussion, based only on the arguments made here:

The complication vector - I think it is likely that, under the rules that apply to outdoor tanks, outdoor tanks can, in most instances, be located and constructed in ways that are a more affordable solution to storage problems, if such problems exist in your jurisdiction,  than  indoor tanks. You need to wade through the rules on that, but if you are located in on property where you can put an outside tank, you may want to consider doing so if the local authorities are making indoor solutions expensive. 

The complexity vector - However, before you purchase tanks for outside use, it would be prudent to talk with with the the agency to see what rules they will apply to the tanks.   Further - this is my interjection - if I were you, I would want to know what the rules say even if they agency with jurisdiction is not inclined to enforce them.  What that agency says today may have no bearing on what it says tomorrow.

The TTB vector - Returning to what I do know, the TTB rules for outside tanks and insider tanks basically are the same.  The construction requirements don't vary and the locking requirements do not vary.  However, it is my opinion that TTB often ignores the construction requirements when the tanks are indoor tanks, but that it would not do so when the tanks are outdoor tanks.  I cite, as an example, the ubiquitous, stackable, plastic totes. 

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2 hours ago, dhdunbar said:

 

Here is my reading of this discussion, based only on the arguments made here:

The complication vector - I think it is likely that, under the rules that apply to outdoor tanks, outdoor tanks can, in most instances, be located and constructed in ways that are a more affordable solution to storage problems, if such problems exist in your jurisdiction,  than  indoor tanks. You need to wade through the rules on that, but if you are located in on property where you can put an outside tank, you may want to consider doing so if the local authorities are making indoor solutions expensive. 

The complexity vector - However, before you purchase tanks for outside use, it would be prudent to talk with with the the agency to see what rules they will apply to the tanks.   Further - this is my interjection - if I were you, I would want to know what the rules say even if they agency with jurisdiction is not inclined to enforce them.  What that agency says today may have no bearing on what it says tomorrow.

 

dhdunder,

I agree with everything that you state here. 

The statement that I made that Thatch is disagreeing with is that I said, in so many words:

Outside storage tanks are a less expensive and much simpler solution in many, if not most situations. 

Then he said:"How would you convey the spirits back indoors for processing?  I'm assuming you can't have a tank outside with a locked valve and piping to an indoor bottling room, for example?  

Then I said: 

"This is really simple. You can use pad lockable valves like dhdunbar suggests or better yet, just plumb to the outside storage tanks and have the valves and pumps inside the building.  I really like nice simple common sense solutions, that save huge amounts of money"

 

Thatch, you keep trying to shift the argument and put words in my mouth, I never said anywhere that a person should not do their due diligence before they purchase tanks.  

I have said 2 things:

Firstly: I answered your question: How would you convey the spirits back indoors for processing?  By stating "This is really simple. You can use pad lockable valves like dhdunbar suggests or better yet, just plumb to the outside storage tanks and have the valves and pumps inside the building."  My statement here is undeniably true.  It is an undeniable fact, that from a mechanical perspective this is very simple solution to a very simple problem.  I originally answered the question from a mechanical perspective as that is the way that I thought that it was proposed to me.  In fact, if you look at the question, that certainly appears to be the case.

 

Second:  You came back saying, in so many words, that it would be very complicated to put the tanks outside and get the plumbing done and then said that AHJs decide the placement of storage tanks etc.  You also stated that a code check should be done, which I wholeheartedly agreed with.

What I did say, in so many words is that we deal with AHJs and code enforcement on a regular basis and that we use our wealth of experience and expertise in this area to make things simple concerning installation of outdoor ethanol storage tanks.

Outdoor ethanol storage tanks are looked at basically the same as all tanks storing flammable  liquids/vapors. Flammable material storage tanks are basically everywhere in the city and countryside.  Fuel tanks at gas stations and other businesses, are all installed using the same basic codes and  rules as outdoor ethanol storage tanks..  If we include all of the nat gas storage tanks and propane tanks and all of the lines carrying flammable liquids and gasses into buildings, we can see that we are literally surrounded by these tanks that contain hazardous liquids and vapors.

With ethanol tanks at distilleries, you have some extra rules to deal with from the TTB but those rules do not concern safety.

So my original statement was, in so many words, that outside storage tanks are a less expensive and much simpler solution in most situations compared to indoor ethanol storage tanks.

That statement is absolutely, unequivocally true.  

We work incredibly hard to make sure that our equipment is as safe as possible.  It is very important that all safety and other codes are followed.  We do our best to help our customers through their equipment installation process and follow all of the rules and guidelines laid down by their municipalities etc.

 

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6 hours ago, Thatch said:

The OP was trying to avoid H classification.  You proposed this as a simple solution to stay with F-1.  I will stick to my original post which said don't buy anything before you do a code review.  

There are setbacks from both property lines and buildings called out in Chapter 57

 

Yes, I did propose a simple solution for staying within F-1 and I received a trophy for that. 

I also said that you should do a code check before you purchase.  Doing your due diligence is the common sense thing to do when planning anything of this nature.

 Yes there are set backs and other requirements that you must follow but you decide where you put your tanks, not the AHJ.   You also use the code guidelines to decide where to place your still, but that as well is your decision, not the AHJs.  

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44 minutes ago, Southernhighlander said:

Thatch, you keep trying to shift the argument and put words in my mouth

I'm not sure why you would think this.  My position all along has simply been that a code review should be done before any money has been spent.  I have provided many reasons why it is prudent to do so and why an aboveground tank may not be a simple solution.  

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2 hours ago, dhdunbar said:

 

No one including my self argued against your position that a code review is a good idea.  As far as an above ground storage tank being a simpler solution than an indoor storage tank,  in most instances, it is and that is undeniable.

 

As far as your question: "How would you convey the spirits back indoors for processing?" 

My answer was: "This is really simple. You can use pad lockable valves like dhdunbar suggests or better yet, just plumb to the outside storage tanks and have the valves and pumps inside the building."

 

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6 minutes ago, Southernhighlander said:

As far as your question: "How would you convey the spirits back indoors for processing?" 

My answer was: "This is really simple. You can use pad lockable valves like dhdunbar suggests or better yet, just plumb to the outside storage tanks and have the valves and pumps inside the building."

You might want to read the thread again.  I never asked you any question that I am aware of.

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2 minutes ago, Thatch said:

You might want to read the thread again.  I never asked you any question that I am aware of.

Sorry,  Nabtastic asked that question and you replied to my answer. 

My answer to his questions was. "This is really simple. You can use pad lockable valves like dhdunbar suggests or better yet, just plumb to the outside storage tanks and have the valves and pumps inside the building". Sounds simple enough to me.  

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I attached one of the drawings that we use to help give our customers an idea of what to expect concerning hazardous environments around stills.  Generally the AHJs have this same interpretation of code, but we have had a couple of outliers.  We had one or two different AHJs classify the area right around the manway as a class 1 div 1.  Our agitators are good for class 1 Div 1 so that is not a problem.  We had one AHJ classify the area around the drain valve of the pot as class 1 div 1 which is a major difference in interpretation  These are the only outliers that we have had so far out of the over 300 distilleries that we have supplied stills to.  Of course the size of the hazardous areas can vary with the size of the still and other factors.  In many places such as rural areas and in the south east AHJs have less stringent requirements, however we always build to meet the international fire safety codes as well as the NEC, UL and ASME requirements.

  When looking at the drawing keep in mind that the Authority Having Jurisdiction has broad authority when classifying  areas, so consult with them before doing anything.  We will be doing the same type of drawing for above ground ethanol storage tanks, as the below one for stills, by end of this week.  We have sold several above ground ethanol storage tanks.  We have a customer in Northern MO purchasing a 3,000 gallon UL142 ethanol tank for their Hemp to CBD processing facility that we are outfitting.  We will be doing an even larger one in AR and I will be installing a larger 6,000 gallon above ground ethanol storage tank here on my property before the end of the year.

Hazard area Classification Drawing.jpg

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On 2/25/2019 at 10:33 PM, et1883 said:

we have approved construction plans for 3 added zones for transstore tank storage, each at 240 gal maq.   "I think" those zones need to be studwall/sheetrock with individual fire suppression (sprinkler).  However, Is that NFPA or other requirement?  Or can the zones be chain link fence, so we can use the existing F-1 sprinklers?    That would make construction a lot        simpler.   Fire services contractor is recommending chain link, as sprinklers will active at 150 degrees. 

The attached file spells it out pretty clearly.  One hour fire protection between control areas and between your F-1 space and a control area.  

201903050718.pdf

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On 2/25/2019 at 10:33 PM, et1883 said:

individual fire suppression

The building code seems to indicate the entire building having sprinklers being what is necessary to double your MAQ.  Are they really making you sprinkle each control area individually to go from 120 to 240?

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