ࡱ> M |bjbj== UWWCxvl$P<(2z2(ZZZb"B$X%\$$ D+%!!|%%+)ZZ@)))%ZZ)%))b2FُɗZ `^P'HTɗ<Ƙl2=ԝ(ԝɗ)Pretreatment Compliance Inspection Summary Report Discharger: City of San Bernardino Location: 399 Chandler Place, San Bernardino, California 92408 Contacts: Andy Coady, Environmental Control Officer Mike Plasencia, Environmental Control Technician Inspection Dates: April 2728, 2004 Inspected By: Najah Amin, Regional Water Quality Control Board Michelle Ittes, Tetra Tech, Inc. Contents  TOC \o "1-3" \h \z   HYPERLINK \l "_Toc75221972" 1. Executive Summary  PAGEREF _Toc75221972 \h 1  HYPERLINK \l "_Toc75221973" 2. Introduction  PAGEREF _Toc75221973 \h 1  HYPERLINK \l "_Toc75221974" 2.1 Size of Program  PAGEREF _Toc75221974 \h 2  HYPERLINK \l "_Toc75221975" 2.2 Description of the Citys Wastewater Plant  PAGEREF _Toc75221975 \h 2  HYPERLINK \l "_Toc75221976" 3. Pretreatment Program Modifications  PAGEREF _Toc75221976 \h 2  HYPERLINK \l "_Toc75221977" 4. Nondomestic Discharger Characterization  PAGEREF _Toc75221977 \h 3  HYPERLINK \l "_Toc75221978" 5. Local Limits  PAGEREF _Toc75221978 \h 4  HYPERLINK \l "_Toc75221979" 6. Control Mechanisms  PAGEREF _Toc75221979 \h 4  HYPERLINK \l "_Toc75221980" 7. Application of Pretreatment Standards and Requirements  PAGEREF _Toc75221980 \h 5  HYPERLINK \l "_Toc75221981" 8. Compliance Monitoring  PAGEREF _Toc75221981 \h 6  HYPERLINK \l "_Toc75221982" 8.1 Compliance Sampling  PAGEREF _Toc75221982 \h 6  HYPERLINK \l "_Toc75221983" 8.2 Compliance Inspections  PAGEREF _Toc75221983 \h 6  HYPERLINK \l "_Toc75221984" 8.3 Nondomestic Discharger Site Inspections Conducted During the Inspection  PAGEREF _Toc75221984 \h 6  HYPERLINK \l "_Toc75221985" 8.4 Requesting, Receiving, and Analyzing Reports  PAGEREF _Toc75221985 \h 7  HYPERLINK \l "_Toc75221986" 8.5 Slug Discharge Control Plans  PAGEREF _Toc75221986 \h 8  HYPERLINK \l "_Toc75221987" 9. Enforcement  PAGEREF _Toc75221987 \h 8  HYPERLINK \l "_Toc75221988" 10. Summary of Findings, Requirements, and Recommendations  PAGEREF _Toc75221988 \h 9  Attachments Attachment A WENDB Data Worksheet Attachment B RNC Data Worksheet Attachment C Nondomestic User Information: Southwest Data Products Attachment D Nondomestic User Information: BAS Recycling, Inc. Attachment E Nondomestic User Information: Juice Harvest Corporation Attachment F Nondomestic User Information: JSP International Attachment G Nondomestic User Information: Rayne Water Conditioning Attachment H Nondomestic Discharger Site Visit Sheets 1. Executive Summary The Santa Ana Regional Water Quality Control Board (Regional Board), with assistance from Tetra Tech, Inc., conducted a Pretreatment Compliance Inspection (PCI) of the City of San Bernardino (City) on April 2728, 2004. The last Pretreatment Compliance Audit (PCA) of the Citys pretreatment program was performed in February 2003. This inspection report describes the primary concerns generated by the PCI. The Citys staff manages a pretreatment program that consists of 385 permitted nondomestic dischargers. Seven of these dischargers are classified as significant industrial users (SIUs), and one of the SIUs is a categorical industrial user (CIU). There are 377 other regulated nonsignificant nondomestic dischargers. The members of the staff, including the newest member, appear to have a good general grasp of the pretreatment requirements, and the inspector seemed to have a thorough knowledge of his respective nondomestic users. The City should be commended for the continued improvement of the pretreatment program over the last year. In a number of areas, however, the program is in need of improvement. One concern is that the City is inappropriately comparing local limits and federal limits to determine which is more stringent. In addition, it is undetermined how the City is applying the limits in the event a resample event takes place within the same calendar month. In addition, the Citys SUO and discharge permits fail to identify the total toxic organic (TTO) pollutants to be monitored, and 40 CFR Part 136 methods are not being used for all analyses. Finally, slug discharge control plan evaluations are not being conducted. 2. Introduction The PCI consisted of three parts: an interview of City staff, a review of the pretreatment program files, and site visits to various permitted industries. The interview included a discussion with several members of the City staff regarding the program in general, the Citys compliance sampling and inspection procedures and their frequency, and enforcement issues. The file review consisted of examining the files of several nondomestic dischargers. To provide a general overview of the pretreatment program, the files were selected based on the classifications of the nondomestic dischargers. The files of the following dischargers were reviewed during the PCI: Southwest Data Products (CIU subject to 40 CFR Part 433) BAS Recycling, Inc. (CIU subject to 40 CFR Part 428, a zero-discharger) Juice Harvest Corporation (Noncategorical SIU) JSP International (Noncategorical SIU) Rayne Water Conditioning (Other regulated nonsignificant nondomestic discharger) Several permitted dischargers were also inspected as part of this inspection. The inspector from Tetra Tech, Inc., and the Regional Board accompanied the City inspectors to assess whether inspection procedures were adequate. To ensure a representative cross section of the Citys pretreatment program, the dischargers were selected for inspection based on classification and current compliance status. The facilities of the following dischargers were visited during the PCI: Southwest Data Products (CIU subject to 40 CFR Part 433) BAS Recycling, Inc. (CIU subject to 40 CFR Part 428 - Zero-discharger) Juice Harvest Corporation (Noncategorical SIU) Rayne Water Conditioning (Other regulated nonsignificant nondomestic discharger) This report summarizes the overall findings of the inspection and describes those program elements that are not consistent with federal pretreatment program requirements. In addition, the report provides recommendations to enhance the effectiveness of program implementation and enforcement. 2.1 Size of Program The Citys pretreatment program consists of 385 permitted nondomestic dischargers. Seven of these dischargers are classified as SIUs as defined at 40 CFR 403.3(t). They include one CIU subject to federal categorical pretreatment standards. The remaining 377 permitted nondomestic dischargers consist of two CIUs certified as zero-dischargers, dental offices, auto repair shops, car washes, water conditioning, facilities with silver recovery systems, and restaurants. 2.2 Description of the Citys Wastewater Plant The City owns and operates a wastewater treatment plant (WWTP) that provides service to approximately 185,000 people and has a dry weather influent flow of 28 million gallons per day (MGD). The WWTP has a design capacity of 33 MGD. The City of Loma Linda, City of Highland, Inland Valley Development Agency, Patton Hospital, and unincorporated areas of San Bernardino County are contributing jurisdictions to the WWTP. The City discharges up to 26 MGD of secondary treated municipal wastewater to the Rapid Infiltration-Extraction (RIX) Facility. The RIX facility is a regional tertiary treatment facility owned by a joint powers authority, which includes the City of San Bernardino and the City of Colton. 3. Pretreatment Program Modifications The federal pretreatment regulations at 40 CFR 403.18 require the City to notify the Regional Board of any modifications it intends to make to its pretreatment program. The City is in the process of modifying its Sewer Use Ordinance (SUO) and Enforcement Response Plan (ERP). At the time of the inspection, the City was working on the final drafts of the SUO and ERP modifications which will include; revising the classification of nondomestic dischargers, language clarification, incorporating grease hauler permits, revising reporting requirements, and enforcement clarification and penalties. In addition, the SUO has also been revised, based on the recommendation from the previous PCA, to include that the local limit values are to be applied as average daily maximum values as identified in the nondomestic discharge permits. A copy of the draft SUO was not provided to the inspection team. The City did not want a copy created until the draft SUO could be completed and submitted to the Regional Board. According to City staff, the draft SUO and ERP will be submitted to the Regional Board in May 2004. The City is reminded that if the modifications are considered substantial, as defined at 40 CFR 403.18(b), the modifications must be reviewed and approved by the Regional Board before any substantial modifications can be implemented. If the modifications are nonsubstantial, the City is required to notify the Regional Board of these modifications at least 45 days before the implementation of the modifications. 4. Nondomestic Discharger Characterization The federal pretreatment regulations at 40 CFR 403.8(f)(2) require that POTWs develop and implement procedures to identify and locate industrial users that might be subject to the local pretreatment program. These procedures must also include proper categorization of all SIUs as defined at 40 CFR 403.3(t). The inspection team found the Citys procedures for identifying nondomestic dischargers adequate. According to City staff, the inspectors are in the process of conducting inspections at all licensed businesses within their jurisdiction. The City divided the jurisdictions into a grid pattern and within the last year conducted inspections at each business to determine if any pretreatment equipment or devices were present. Each business is issued a control number and will be periodically inspected by the City in the future. If any pretreatment equipment was identified, the business is required to complete an application and a nondomestic discharge permit is issued. In addition, the City reviews all business permits prior to new business startup, and attends weekly Environmental Development Committee meetings. According to City staff, the WWTP was experiencing periodic elevated electrical conductivity spikes on the Arrowhead Sewage Pipeline. According to a City memorandum dated March 16, 2004, the conductivity spikes was associated with total dissolved solids and contributing pollutants, which increased the salt loading received at the WWTP. This could impact the Citys ability to comply with the discharge requirements specified in their National Pollutant Discharge Elimination System (NPDES) permit. According to the Arrowhead High Conductivity Investigation Report, dated February 12, 2004, an investigation from April 2003 to January 2004 resulted in the identification of Rayne Water Conditioning discharging wastewater with elevated concentrations of sodium and chloride, which is consistent with the type of high strength brine wastewater generated from their processes. Enforcement was initiated and is discussed in Section 8 of this report. 5. Local Limits The federal pretreatment regulations at 40 CFR 403.5(c) require publicly owned treatment works (POTWs) to develop and enforce local limits to implement the general and specific prohibitions at 40 CFR 403.5(a) and (b). The pretreatment regulations also require POTWs to continue to develop these local limits as necessary and effectively enforce the limits. Furthermore, the National Pollutant Discharge Elimination System (NPDES) regulations at 40 CFR 122.44(j)(2)(ii) require POTWs to provide a written technical evaluation of the need to revise local limits following permit issuance and reissuance. The City could not determine how the local TTO limit was developed. The TTO local limit identified in the SUO for all SIUs is 2.13 milligrams per liter (mg/L). This limit is identical to the TTO parameter listed in 40 CFR 433.10. The City is required to determine the technical basis for the TTO local limit of 2.13 mg/L. As noted in the previous PCA, the City does not identify the TTO pollutants regulated by its local limit in the SUO or in the permits. Because the City does not specify which pollutants should be included as part of its TTO pollutants list and there are varying TTO lists between different federal categorical industries, there is no way to evaluate whether a discharger is monitoring for all of the required pollutants to evaluate compliance with the local TTO limit. Once the City has determined the technical basis for its TTO limit, the City is required revise its SUO to include its definition of TTO that includes a specific limit of pollutants. The City should also revise the discharge permits to include the specific TTO pollutants to be monitored. 6. Control Mechanisms The federal pretreatment regulations at 40 CFR 403.8(f)(1)(iii) require POTWs to control through control mechanisms (permits or other similar means) the discharges from nondomestic dischargers to ensure compliance with applicable pretreatment standards. The control mechanisms are required, at a minimum, to include the following: Statement of duration (in no case more than 5 years) Statement of nontransferability Effluent limits Self-monitoring, sampling, reporting, and record-keeping requirements Statement of penalties Compliance schedules (if applicable) Required resampling within 30 days after noticing a violation Notification requirements Notice of slug loadings Notification of spills, bypasses, or upsets Notification of significant change in discharge Notification within 24 hours after noticing a violation Permits for CIUs must also properly use the combined wastestream formula, properly convert mass-based limits to concentration-based limits, and properly apply production-based limits (if applicable) and must include a prohibition on dilution as a substitute for treatment. In general, the Citys permits were well written and easy to follow. The following issues were identified during the file review. 40 CFR 403.8(f)(1)(iii)(E) requires that all SIU permits contain a statement of applicable civil and criminal penalties for a violation of pretreatment standards and requirements. For all files reviewed, the civil and criminal penalties statement found in Part V-Special Conditions, Section D, fails to stipulate the penalty amounts that may be applied to the permittee in the event the permitee does not comply with all conditions of the discharge permit. The City is required to revise the discharge permits to include penalty amounts as defined in the Citys SUO. 7. Application of Pretreatment Standards and Requirements The federal pretreatment regulations at 40 CFR 403.8(f)(1) require the City to have the legal authority to require compliance with applicable pretreatment standards and requirements, and to ensure compliance with these standards and requirements through the use of control mechanisms such as permits. The City is inappropriately evaluating the most stringent limit between local daily maximum limits, the federal daily maximum limits, and the federal monthly average limits. Southwest Data Products discharge permit identifies that the local limits, and the federal daily maximum and monthly average limits, are to be applied to the dischargers wastewater effluent. The City, however, is only applying the most numerically stringent of the 3 limits. Local limits and federal limits are not comparable. Local limits are applied at end-of-pipe while federal categorical limits are applied at end-of-process. Southwest Data Products sampling point is, however, both end-of-process and the end-of-pipe. Therefore, the local daily maximum limit and the federal daily maximum limit would be comparable and the more stringent limit would apply. In addition, the City is also required to evaluate the average of all sample results within a calendar month with the federal categorical monthly average limits. Even if only one sample is taken during a calendar month, the sample result must comply with both the more stringent daily maximum limit and the federal monthly average limit. Furthermore, daily maximum limits and monthly average limits are not comparable because compliance with a daily maximum limit is based a sample result from a 24-hour period while compliance with a monthly average limit is based an average of all the sample results taken during a calendar month. Therefore, in the event that more than one sample is taken of a pollutant during a calendar month, all of the results must be averaged, and the average value is then compared to the monthly average limit for compliance. In the event that more than one sample is taken of a pollutant during a calendar month, based on discussion with City staff, it appears that assessment of compliance with monthly average limits had not been addressed in this manner in the past. The City is required to revise Southwest Data Products discharge permit to indicate that the federal monthly average limit is applicable for all sampling results. The City is also required to evaluate compliance with the federal monthly average limits. 8. Compliance Monitoring The federal pretreatment regulations at 40 CFR 403.8(f)(2)(v) require that a POTW develop and implement an inspection and monitoring program to determine, independent of information supplied by nondomestic dischargers, compliance or noncompliance with applicable pretreatment standards and requirements. Furthermore, 40 CFR 403.8(f)(2)(vi) requires POTWs to investigate instances of noncompliance and enforce the regulations as necessary. 8.1 Compliance Sampling The federal pretreatment regulations at 40 CFR 403.8(f)(2)(v) require that all SIUs be sampled at least once a year. The City currently conducts sampling at all SIUs during the second and fourth quarters. Based on review of the permit files the Citys compliance sampling frequency was found to be adequate. The Citys compliance sampling procedures, however, were found to be deficient. The file review revealed that the City is using incorrect analytical methods for chloride during its compliance sample analysis. The laboratory results indicated that EPA Method 300.0 was used. 40 CFR Part 136 requires EPA method 325.3 be utilized for chloride. The City is required to ensure that 40 CFR Part 136 methods are used for all compliance sampling analysis. 8.2 Compliance Inspections The federal pretreatment regulations at 40 CFR 403.8(f)(2)(v) require that all SIUs be inspected at least once a year. The City currently conducts sampling at all SIUs on a quarterly basis. Based on review of the permit files, the Citys compliance inspection frequency was found to be adequate. 8.3 Nondomestic Discharger Site Inspections Conducted During the Inspection The inspection team, along with City staff, inspected four of the permitted nondomestic dischargers as part of the inspection. The dischargers were selected to represent facilities of varying size, classification, and current compliance status. The Tetra Tech inspection team noted the following during the nondomestic discharger site visits: Southwest Data Products. This facility manufactures metal cabinets for the telecommunication industry. The dischargers operations include shearing flat sheets of metal to designated sizes. The metal sheets are then fabricated, punched, and formed into specific parts. The parts are assembled, welded, washed, and baked dry. Finally, the assembled parts are powder coated and baked. The production warehouse was found to be clean and organized. No deficiencies were noted during the inspection. BAS Recycling, Inc. This facility reclaims whole used automotive and truck tires for recycling. The company buys recycled crumb rubber (pieces of different sized rubber) from a parent company. The rubber is used to manufacture rubber asphalt, athletic surfacing, and molded rubber products. Rubber pieces are dyed according to customer specifications, molded in a heating press, and air-cooled. This facility is a CIU Zero discharger. The production area was completely enclosed with no floor drains. No deficiencies were noted during the inspection. Juice Harvest Corporation. This facility processes all natural fruit and vegetable juice products. Operations include processing fresh fruits and vegetables, packaging salads, salad dressings, salsa, fruit salad, fresh sliced fruit and vegetables, and fresh cooked vegetable soup. Raw fruits and vegetable are received, sorted, and removed from their shipping boxes. Raw products are washed and rinsed with a chlorine solution. All final products are shipped the same day they are cut, processed, and packaged to specialty food stores. The facility was clean and organized. Fruit and vegetable skins and other parts are recycled and shipped to a cattle feed manufacturer. The facility is under a compliance order to install a flow meter and a pH neutralization system. The facility is working closely with the City to ensure compliance. No deficiencies were noted during the inspection. Rayne Water Conditioning. The facility is a water-softening regeneration plant. This process includes synthetic resin beads that are covered with soft sodium ions by washing them in a saturated sodium chloride brine solution. The beads are contained in a pressurized vessel tank. Untreated hard water enters the resin tank and passes through the bed of resin. The resin beads exchange the sodium ions for the hard water ions, allowing the soft water to flow from the resin tank. The regeneration tanks are filled and delivered to customers. The process portion of the facility was found to be clean. The facility is currently under a compliance order to install monitoring equipment, develop standard operating procedures and employee training, and submit monthly compliance reports. At the time of the inspection the facility was working closely with the City to ensure compliance. No deficiencies were noted during the inspection. 8.4 Requesting, Receiving, and Analyzing Reports 40 CFR 403.8(f)(2)(iv) requires the City to request, receive, and analyze all reports submitted by SIUs. The City requires all SIUs to perform self-monitoring during first and third quarters. Self-monitoring reports (SMRs) are to be submitted to the City by the last day of the second month, February and August, of the self-monitoring period. For all SMRs reviewed during the PCI, the self-monitoring results indicated that the laboratory was using an incorrect analytical method for chloride. The laboratory results indicated that EPA Method 300.0 was used. 40 CFR Part 136 requires EPA Method 325.3 be utilized. The City is required to ensure that 40 CFR Part 136 methods are being used for self-monitoring analysis. 8.5 Slug Discharge Control Plans 40 CFR 403.8(f)(2)(v) requires the City to evaluate each SIU, at least once every 2 years, to determine whether the SIU needs to develop and implement a slug discharge control plan. A slug discharge is any discharge of a nonroutine, episodic nature, including an accidental spill or noncustomary batch discharge [40 CFR 403.8(f)(2)(v)]. The City has updated their discharge permit applications to include a Slug Load Control Plan (SLCP) section to be completed by the industry. All industries submitting an application to the City is required to complete this section once every three years. Upon review of the SLCP section, all of the federal minimum requirements were met except requesting a written description of the industries discharge practices. The City is required to revise the SLCP section in the discharge permit application to include the minimum slug discharge control plan requirements. In addition, there was no written documentation of an industrys need to develop and implement a slug discharge control plan or any written evaluations of existing plans. Even though the discharge permit application contains a section to be completed by the industry regarding slug load control plans, the application is only submitted to the City once every three years. The slug control plan evaluation is required at least once every two years as defined in 40 CFR 403.8(f)(2)(v). The inspection team recommends that the City revise the inspection form to include the evaluation of the dischargers need for a slug discharge control plan. Juice Harvest Corporation was required by the City to submit a slug discharge control plan. Juice Harvest Corporation worked closely with the City to create a plan and submitted a document entitled Waste Water Discharge Control Plan. As part of this PCI, the plan was reviewed and was found to be inadequate for not meeting the minimum requirements in 40 CFR 403.8(f)(2)(v). The plan focused on spill prevention, spill abatement procedures, and contained storm water pollution prevention information and procedures. The City is required to review the plan and require Juice Harvest Corporation to revise the plan to include the minimum slug discharge control plan requirements. 9. Enforcement 40 CFR 403.8(f)(5) requires the City to develop and implement an ERP. This plan must contain detailed procedures indicating how the City will investigate and respond to instances of industrial user noncompliance. The City is currently in the process of revising the ERP and according to City staff, plan on submitting the draft ERP to the Regional Board in May 2004. A copy of the draft ERP was not provided to the inspection team. The City did not want a copy created until the draft ERP could be completed and submitted to the Regional Board. The City is currently following the original draft ERP, as described in the previous PCA. According to the interview with City staff, and file review, the City is following the guidelines set forth in the original draft ERP. The City was experiencing periodic elevated electrical conductivity spikes on the Arrowhead Sewage Pipeline. According to the Arrowhead High Conductivity Investigation Report, dated February 12, 2004, the investigation from April 2003 to January 2004 resulted in the identification of Rayne Water Conditioning discharging wastewater with elevated concentrations of sodium and chloride. On March 16, 2004 an Issuance of Notice of Violation Cease and Desist Order was issued to Rayne Water Conditioning describing the results of the investigation and issuing a Compliance Order. According to documentation provided during the interview and information obtained in the file, Rayne Water Conditioning is working with the City to ensure compliance and has complied with the dates set forth in the Compliance Order as well as any extension requests granted by the City. The City is working closely with this industry and is following the guidelines set forth in the ERP. 10. Summary of Findings, Requirements, and Recommendations Listed below are the primary requirements and recommendations resulting from the inspection of the Citys pretreatment program. For more specific information pertaining to each comment, please refer to the cited sections of the report. The TTO local limit identified in the SUO for all SIUs is 2.13 mg/l. This limit is identical to the TTO parameter listed in 433.10, which applies to Southwest Data Products, the Citys only CIU. The technical basis for the TTO limit is undetermined. The City is required to determine the technical basis for the TTO local limit of 2.13 mg/l. (Section 5, Local Limits) The discharge permits failed to identify a list of the required TTO pollutants to be monitored. The City is required to revise the SUO to identify the required TTO pollutants to be monitored as identified in the previous PCA. In addition, the City should include a list of applicable TTO pollutants in each SIU permit. (Section 5, Local Limits) The discharge permits failed to stipulate the civil penalty amounts that may be applied for a violation of pretreatment standards. 40 CFR 403.8(f)(1)(iii)(E) requires that all SIU permits contain a statement of applicable civil and criminal penalties for violations of pretreatment standards and requirements. The inspection team recommends that the City revise the discharge permits to include the penalty amounts as defined in the Citys SUO. (Section 6, Control Mechanisms) The City is inappropriately evaluating the most stringent limit between local daily maximum limits, the federal daily maximum limits, and the federal monthly average limits. In the event that more than one sample is taken of a pollutant during a calendar month, it is undetermined how the City would address this issue. The City is required to revise Southwest Data Products discharge permit to indicate that the federal monthly average limit is applicable for all sampling results. The City is also required to evaluate compliance with the federal monthly average limits. (Section 7, Application of Pretreatment Standards and Requirements) Incorrect analytical methods for chloride are being used for compliance and self-monitoring events. 40 CFR 403.12(b)(5)(vi) states that sampling and analysis shall be performed in accordance with techniques prescribed 40 CFR 136. The City is required to ensure that 40 CFR Part 136 methods are being applied for all sampling events. (Section 7.1 Compliance Sampling) The Citys discharge permit application include a SLCP section to be completed by the industry that does not meet all the requirements as identified in 40 CFR 403.8(f)(2)(v). The City is required to revise the SLCP section of the discharge permit application to include the required description of the industries discharge practices. (Section 7.5 Slug Discharge Control Plans) The City is not documenting an industrys need to develop and implement a slug discharge control plan or documenting evaluations of existing plans. The slug control plan evaluation is required at least once every two years as defined in 40 CFR 403.8(f)(2)(v). The inspection team recommends that the City revise the inspection form to include the evaluation of the dischargers need for a slug discharge control plan. (Section 7.5 Slug Discharge Control Plans) The Waste Water Discharge Control Plan submitted to the City by Juice Harvest Corporation failed to meet the requirements as defined in 40 CFR 403.8(f)(2)(v). The City is required to review the plan and ensure that Juice Harvest Corporation revise the plan to meet the minimum slug discharge control requirements. 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