HomeMy WebLinkAbout080513_ca08SON COL
Consent Agenda
JEFFERSON COUNTY PUBLIC HEALTH
615 Sheridan Street o Port Townsend o Washington o 98368
www.jeffersoncountypublichealth.org
July 18, 2013
JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO: Board of County Commissioners
Philip Morley, County Administrator
FROM: Jared Keefer, Environmental Health & Water Quality Director
DATE: Ali j 5 i
SUBJECT: Agenda Item — Interagency Agreement with Department of Ecology for
Local Source Control; July 1, 2013 — June 30, 2015; $175,000
STATEMENT OF ISSUE:
Jefferson County Public Health, Environmental Health Department, is requesting Board approval of the
Interagency Agreement with Department of Ecology for Local Source Control; July 1, 2013 — June 30, 2015;
$175,000
ANALYSIS /STRATEGIC GOALS /PRO'S and CON'S:
JCPH Local Source Control Specialist (LSCS) will visit Jefferson County businesses to provide no -cost
technical assistance site visits to reduce pollution to our water resources. The program goal is to reduce
and eliminate hazardous wastes and pollutants and protect surface waters.
Through individual consultation, the LSCS will work with business owners to evaluate their businesses
practices and make recommendations to reduce their impacts on the environment and make
recommendations based on Best Management Practices for that industry.
The LSCS will work closely with the City of Port Townsend to provide source control expertise and
education /outreach on stormwater pollution prevention and conduct internal inspection of the County and
City maintenance facilities to ensure source control standards are being met. LSCS will also investigate
businesses that are connected to an on -site septic system (OSS) to ensure hazardous waste is being
properly disposed and managed. In some cases where it is determined that hazardous waste is disposed
into the OSS, LSCS will collect samples from the OSS and identify possible contamination. Contamination
into these systems causes system failures and can result in subsurface flow into surface waters.
FISCAL IMPACT /COST BENEFIT ANALYSIS:
This contract is funded by Department of Ecology at 100 %.
COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH
DEVELOPMENTAL DISABILITIES WATER QUALITY
MAIN: (360) 385 -9400 ALWAYS WORKING FOR A SAFER AND MAIN: (360) 385 -9444
FAX: (360) 385 -9401 HEALTHIER COMMUNITY FAX: (360) 379-4487
Consent Agenda
RECOMMENDATION:
JCPH management request approval of the Interagency Agreement with Department of Ecology for Local
Source Control; July 1, 2013 — June 30, 2015; $175,000
REVIEWED BY:
i'
ONW'Morley, ty rator
Date
0
DEPARTMENT OF
ECOLOGY
State of Washington
IAA No. C1400033
INTERAGENCY AGREEMENT (IAA)
BETWEEN
THE STATE OF WASHINGTON, DEPARTMENT OF ECOLOGY
AND
JEFFERSON COUNTY PUBLIC HEALTH
THIS INTERAGENCY AGREEMENT is made and entered into by and between the STATE OF
WASHINGTON, DEPARTMENT OF ECOLOGY, hereinafter referred to as "ECOLOGY," and Jefferson
County Public Health , hereinafter referred to as the "CONTRACTOR" pursuant to the authority granted by
Chapter 39.34 RCW.
IT IS THE PURPOSE OF THIS AGREEMENT to provide funding for the CONTRACTOR to hire a
"Local Source Control Specialist" (LSCS) who will provide technical assistance and education outreach to
small businesses in an effort to prevent pollution of the urban waters of the state. The LSCS will make
referrals to ECOLOGY as needed, and report measurable environmental results.
THEREFORE, IT IS MUTUALLY AGREED THAT:
The CONTRACTOR will conduct multimedia source control site visits and pollution prevention activities
to Conditionally Exempt Small Quantity Generator (CESQG) businesses that are designed to reduce or
eliminate hazardous waste and pollutants at the source.
Ecology will coordinate this partnership through a Local Source Control Program Coordinator, and
support collaborative efforts to protect and restore Puget Sound and the Spokane River Watershed.
1) STATEMENT OF WORK
CONTRACTOR shall furnish the necessary personnel, equipment, material and/or service(s) and otherwise
do all things necessary for or incidental to the performance of the work set forth in Attachment A, and for
federally- funded partners, Attachment C, attached hereto and incorporated herein.
2) PERIOD OF PERFORMANCE
Subject to its other provisions, the period of performance of this IAA shall commence on July 1, 2013, and
be completed by June 31, 2015, unless terminated sooner as provided herein. Ecology reserves the right to
review the contract after one year and adjust the scope of work and budget according to actual performance.
3) PAYMENT
Compensation for the work provided in accordance with this IAA has been established under the terms of
RCW 39.34.130 and in accordance with Governor's Executive Order 10 -07. This is a performance -based
contract, in which payment is based on the successful completion of expected deliverables. The parties
have determined that the cost of accomplishing the work herein will not exceed $175,000. Payment for
satisfactory performance of the work shall not exceed this amount unless the parties mutually agree to a
higher amount. Compensation for services shall be based on the terns set forth in accordance with the tasks
listed in Attachment A, Statement of Work and Attachment B, Invoice & Budget Detail, which is attached
hereto and incorporated herein. ECOLOGY will not make payment until it has reviewed and accepted the
completed work.
All travel expenses for state and federally funded partners (meals, lodging, mileage) will be reimbursed
according to current state rates at the time of travel, Nvww.ofm.wa.gov/resources/travel/colorrn4p.pdf.
Purchase of source control tools for distribution to CESQG businesses may not exceed $2,500.00 for the 24-
month contract period. Any purchases of equipment or goods over $1,000 must be pre- approved by the LSC
Program Coordinator.
4) OVERHEAD AND INDIRECT CHARGES
Ecology prefers this rate to be charged on Salaries and Benefits only. If the pannerjurisdiction calculates this
on a different base, attach a complete explanation of the items in the base. Indicate the rate in the cell
provided on Attachment B, Invoice & Budget Detail.
Ecology recognizes annual adjustment to indirect rates. CONTRACTOR is required to notify Program
Coordinator and to clearly indicate the rate change on Attachment B at the time of billing.
5) BILLING PROCEDURE
CONTRACTOR shall submit quarterly invoices to ECOLOGY for payment, within 40 days following the
end of the billing quarter using the state invoice voucher form A19 -IA. All invoices are to be delivered to:
Julia McHugh, HWTR, Dept of Ecology, PO Box 47600, Olympia, WA 98504 -7600.
Each invoice shall reference the Agreement (IAA) number and clearly identify the items related to
performance under this agreement. All expenses invoiced shall be supported with copies of invoices paid.
Upon expiration of the Agreement, any claim for payment not already made shall be submitted within 30
days after the expiration date or the end of fiscal year, whichever is earlier. Payment will be within 30 days of
receipt of properly completed invoice.
Payment for approved and completed work will be issued through Washington State's Department of
Enterprise Services Statewide Payee Desk. To receive payment you must register as a state -wide vendor
by submitting a state -wide vendor registration form and an IRS W -9 form at website,
http- / /www des wa gov/ services /ContractinfPurchasing/ Business /Vendoi-Pav /Pages /default.aspx. If you
have questions about the vendor registration process you can contact DES at the Payee Help Desk at
(360) 407 -8180 or email payeehelpdesk(az)des.wa.gov.
6) AGREEMENT ALTERATIONS AND AMENDMENTS
This Agreement may be amended by mutual agreement of the parties. Such amendments shall not be binding
unless they are in writing and signed by personnel authorized to bind each of the parties.
7) SUBCONTRACTORS
CONTRACTOR agrees to take complete responsibility for all actions of any Subcontractor used for the
performances under this agreement.
Prior to performance, CONTRACTOR shall identify and notify the LSC Program Coordinator of the
subcontractor(s) who will perform services in fulfillment of agreement requirements, including their name,
the nature of services to be performed, address, telephone, WA State Department of Revenue Registration
Tax number (UBI), federal tax identification number (TIN), and anticipated dollar value of each subcontract.
s) ASSIGNMENT
The work to be provided under this Agreement, and any claim arising thereunder, is not assignable or
delegable by either party in whole or in part, without the express prior written consent of the other party,
which consent shall not be unreasonably withheld.
9) DISPUTES
In the event that a dispute arises under this Agreement, it shall be determined by a Dispute Board in the
following manner: Each party to this Agreement shall appoint one member to the Dispute Board. The
members so appointed shall jointly appoint an additional member to the Dispute Board. The Dispute
Board shall review the facts, agreement terms and applicable statutes and rules and make a determination
of the dispute. The determination of the Dispute Board shall be final and binding on the parties hereto.
As an alternative to this process, either of the parties may request intervention by the Governor, as
provided by RCW 43.17.330, in which event the Governor's process will control.
10) GOVERNANCE AND PRECEDENCE
This Agreement is entered into pursuant to and under the authority granted by the laws of the state of
Washington and any applicable federal laws. The provisions of this Agreement shall be construed to
conform to those laws.
In the event of an inconsistency in the terms of this Agreement, or between its terms and any applicable
statute or rule, the inconsistency shall be resolved by giving precedence in the following order:
a. Applicable Federal and State of Washington statutes, regulations and rules.
b. Mutually agreed written amendments to this Contract.
c. Statement of Work and Budget.
d. Any other provisions of the Agreement, including materials incorporated by reference.
11) INDEPENDENT CAPACITY
The employees or agents of each party who are engaged in the performance of this Agreement shall continue
to be employees or agents of that party and shall not be considered for any purpose to be employees or agents
of the other party.
12) RECORDS MAINTENANCE
The parties to this Agreement shall each maintain books, records, documents and other evidence that
sufficiently and properly reflect all direct and indirect costs expended by either party in the performance of
the service(s) described herein. These records shall be subject to inspection, review or audit by personnel of
both parties, other personnel duly authorized by either party, the Office of the State Auditor, and federal
officials so authorized by law. All books, records, documents, and other material relevant to this Agreement
will be retained for six years after expiration and the Office of the State Auditor, federal auditors, and any
persons duly authorized by the parties shall have full access and the right to examine any of these materials
during this period.
Records and other documents, in any medium, furnished by one party to this agreement to the other party,
will remain the property of the furnishing party, unless otherwise agreed. The receiving party will not
disclose or make available this material to any third parties without first giving notice to the furnishing party
and giving it a reasonable opportunity to respond. Each party will utilize reasonable security procedures and
protections to assure that records and documents provided by the other party are not erroneously disclosed to
third parties.
13) RIGHTS IN DATA
Unless otherwise provided, data which originates from this Agreement shall be "works for hire" as defined by
the U.S. Copyright Act of 1976 and shall be owned by ECOLOGY. Data shall include, but not be limited to,
reports, documents, pamphlets, advertisements, books magazines, surveys, studies, computer programs,
websites, databases, films, tapes, and /or sound reproductions. Ownership includes the right to copyright,
patent, register, and the ability to transfer these rights.
14) SEVERABILITY
If any provision of this Agreement or any provision of any document incorporated by reference shall be held
invalid, such invalidity shall not affect the other provisions of this Agreement which can be given effect
without the invalid provision, if such remainder conforms to the requirements of applicable law and the
fundamental purpose of this agreement, and to this end the provisions of this Agreement are declared to be
severable.
15) TERMINATION
Either party may terminate this Agreement upon thirty (30) days' prior written notification to the other party.
If this Agreement is so terminated, the parties shall be liable only for performance rendered or costs incurred
in accordance with the terms of this Agreement prior to the effective date of termination.
16) TERMINATION FOR CAUSE
If for any cause, either party does not fulfill in a timely and proper manner its obligations under this
Agreement, or if either party violates any of these terms and conditions, the aggrieved party will give the
other party written notice of such failure or violation. The responsible party will be given the opportunity to
correct the violation or failure within 15 working days. If failure or violation is not corrected, this Agreement
may be terminated immediately by written notice of the aggrieved party to the other.
17) WAIVER
A failure by either party to exercise its rights under this Agreement shall not preclude that party from
subsequent exercise of such rights and shall not constitute a waiver of any other rights under this Agreement
unless stated to be such in a writing signed by an authorized representative of the party and attached to the
original Agreement.
18) AGREEMENT MANAGEMENT
The representative for each of the parties shall be responsible for and shall be the contact person for all
communications and billings regarding the performance of this Agreement.
The ECOLOGY Representative is:
The Jefferson County Public Health
Representative is:
Name:
Julia McHugh
Name:
Address:
PO Box 47600
Address:
Olympia, WA 98504 -7600
Phone:
360 - 407 -6850
Phone:
Email:
jmch461 @ecy.wa.gov
Email:
Fax:
360 -407 -6715
Fax:
19) ALL WRI'T'INGS CONTAINED HEREIN
This Agreement contains all the terms and conditions agreed upon by the parties. No other understandings,
oral or otherwise, regarding the subject matter of this Agreement shall be deemed to exist or to bind any of
the parties hereto.
The signatories to this Agreement represent that they have the authority to bind their respective
organizations to this Agreement.
IN WITNESS WHEREOF, the parties have executed this Agreement.
State of Washington
Department of Ecology
Signature
Polly Zehm
Deputy Director
Approved as to form:
Attorney General's Office
Jefferson County Public Health
Signature
Print Name:
Title:
Date
TnCA� rm tml� l ZYI J 3 o. Prosecavid Alvarez, Chief
F
State of Washington, Department of Ecology
IAA No.
Attachment A
FY2013 -15
Jefferson County Public Health
Statement of Work and Program Guidelines
I. Contractor Scope of Work
The Contractor will conduct 150 technical assistance site visits to small quantity generator (SQG)
businesses during the 2013 -15 biennium.
If the partner jurisdiction will pursue a sector focus or particular local activity, describe below:
Sector Focus / Local Activity
Deliverable (limit each description to one sentence)
Educational Facilities /School Districts
Conduct multimedia site visits at educational facilities
Professional Artists
Conduct four hazardous waste seminars to local artists
Fats, Oils, and Grease
Conduct on -site technical assistance visits to food
establishments
Kev Personnel (include Subcontractor(s) if applicable)
Staff
Estimated FTE
Role
Pinky Feria Mingo
.65
LSC Project Lead,
Christy Fiedler
.30
LSC Inspector, Backup /Database
Management
Jared Keefer
.05
Project Supervisor
Contractor
Contractor (Workshop to Artists)
II. Work & Site Visit Allocation
Depending upon jurisdiction conditions, the Local Source Control Specialist (LSCS) work is expected to
fall within these general proportions: 75% Site Visits, 15% Education & Outreach to businesses or
business organizations, 10% Networking / Training.
Depending upon jurisdiction conditions, approximately 70% of the visits will be to new, 'never- visited'
small businesses or those that have not received a LSC site visit in 3 or more years. The balance of
visits are to be follow -up /return visits to resolve any High Priority Environmental Issues (HPEIs) found.
The following nine HPEIs, indicated on page 3, revised LSC Checklist v4.0.3, are Ecology's top priorities
for follow -up visits to ensure correction of the problem. Other issues found on -site and subsequent
follow -up are at the discretion of the local jurisdiction. When unable to resolve the business' HPEIs,
LSCS are to follow Ecology's referral policy, outlined in the 'LSCP Contact and Referral Guide'.
• Hazardous Waste
• Properly designate waste
• Properly dispose of waste
• Properly store products /wastes
• Repair or replace degraded open chemical containers
Stormwater
• Correct illegal plumbing connection
• Halt discharges of process wastewaters to storm drain
State of Washington, Department of Ecology
IAA No.
• Properly store containerized materials
• Properly store non - containerized materials
• Clean and eliminate leaks and spills from storage areas
• Ecology reserves the ability to direct a portion of business site visits towards specific priority sources
or contaminants such as, but not limited to:
• toxics in stormwater;
• copper, mercury, lead, cadmium and / or zinc sources
• vehicle repair, property management, paint & coatings, industrial operations, retail,
marine, healthcare, agriculture, governmental operations, hospitality, school districts
• sources of persistent, bioaccumulative and toxic contaminants (PBTs), such as
Abandoned /Bankrupt sites or outdoor operational washing activities
• Safer Chemistry Challenge Program
• LEAN for Small Quantity Generators (maximize customer value while minimizing waste;
create more value for customers with fewer resources)
• provide UIC Program information to business owners on the use of UIC wells. This would
include providing a UIC Program fact sheet and a paper copy of the Industrial /Commercial
UIC registration form provided by Ecology.
III. Site Visit Requirements
• Coordinate with respective Ecology Regional Offices on an ongoing basis to ensure that businesses
are not being visited by other Source Control or Urban Waters staff, and that the business is not a
Medium or Large Quantity Generator.
Provide technical assistance on waste and toxics reduction, storage, and disposal, and pollution
prevention during on -site visits and follow -up contact. Follow -up assistance and general business
outreach may be letters to or phone consultations with individual businesses, meetings, publications,
newsletters, workshops, providing internet resources, and other forms of technical information
distribution.
• Coordinate and collaborate when developing technical assistance messages and outreach materials
and resources with Ecology technical staff and other internal local government personnel or functions
such as fire marshal, code enforcement, storm water, wastewater treatment plant, and moderate risk
waste staff.
Encourage businesses to participate in local green business programs, including the EnviroStars
business certification program (http: / /envirostars.orgn
• Post all materials developed to educate /assist businesses or to market the LSC Program internally or
externally to the LSC SharePoint site within 30 days of completion of the piece.
• Coordinate with local jurisdictions and Ecology's Regional Office in a timely manner regarding
complaints about or from SQG businesses.
• If completing contracted site visits prior to the end of the contract period, use 70% of remaining time
to do additional site visits.
• For pre -site visit research, a combination of data sources is recommended. A list of suggested
resources is posted on the LSC SharePoint site.
State of Washington, Department of Ecology
IAA No.
IV. Reporting Results to Ecology
Site Visit Data Entry
• Complete a source control checklist for each site visit and enter it into Ecology's LSC database.
The checklist is available as hard copy, and is expected to be available in digital form that can be
completed on a field tool and downloaded to the database online. The partner jurisdiction is
responsible for maintaining original checklist documents for purposes of public disclosure requests
and as historic records.
Data entry is expected to be thorough, complete, and timely. All site visit information collected on the
checklist must be entered in the LSC database within 30 days of each site visit, whether initial,
follow -up, screening, or referral to a regulatory body.
Contractor will ensure all data records are complete (either 'pending', 'closed', or `referred') to
promote quality assurance of the local source control data.
• Credit for these types of site visits will be assigned upon completion of the data record in the LSC
database:
• Site Visit — Complete;
• Site Visit— Follow -Up or Return
• Site Visit —Screening or Incomplete (attempted but turned away);
• Through the 'Reports' feature of the new database, Contractor will be able to retrieve site visit reports
to identify /correct any incomplete data records, and to formulate reports for their jurisdiction.
V. Reporting Changes in Business Practices
The former 'Monthly Report' is replaced by new sections (pg 4, revised LSC Checklist v4.0.3), including
"Changes in Business Practices, Cost of Structural or Other Changes Made by Business, Refer to Safer
Chemicals, Refer to Envirostars, Refer to Energy Efficiency Resource ".
It is required that these new sections are populated where applicable for each site in order to quantify
the effectiveness of LSCS work. These new categories will aid in tracking business behavior change,
the costs incurred to make the change(s), and any cost savings realized by the business.
VI. Reporting Other Changes to Ecology
Report to the LSC Program Coordinator when applicable:
• Any potential program, contract, or small business client problems and resolutions
• Any key personnel changes
• Initiation or changes to a subcontract or subcontractor information
VII. Invoicing
Quarterly invoices for completed work will be submitted on Ecology- provided, original, signed Form A-
19-1A, and detailed on Attachment B, Invoice Detail. An original signed Invoice, Invoice Detail, and
supporting invoice detail documentation will be sent within 40 days of the end of the invoice quarter to the
Contract/Project Manager: Julia McHugh imch461Ca)_ecy.wa.crov 360 - 407 -6850
Washington State Department of Ecology Hazardous Waste and Toxics Reduction Program
PO Box 47600 Olympia, WA 98504 -7600
State of Washington, Department of Ecology
IAA No.
VIII. Establishment of Local Source Control Specialist Training Plan and
Role of Ecology's LSC Training Coordinator
Results from the February 2013 LSC Program Survey pointed to the need for an improvement in the
Specialists' training program, in particular, a more rigorous new -hire training component and an
improved progression for overall training. An Ecology Training Coordinator and part-time assistant will
establish and facilitate the training program. All Specialists are expected to participate.
A. New Hire Evaluation
1. The LSC Training Coordinator will develop an introductory diagnostic evaluation to assess the
level of training needed by newly hired LSCS, and to enable modification of the on -going training
plan. It will consist of ten questions - two from each area listed below. The questions will help
determine competency in each core area and will be administered within two months of joining
the LSC program.
Where the new LSCS shows competency, there will be no additional training requirement for that
category. Conversely where the competency is not high, more training will be provided.
General Training Categories include, but are not limited to:
I. Storm Water Inspections
ll. Hazardous Waste (40 CFR/WAC 173 -303) (emphasis on Designation and waste codes)
III. Solid Waste (with an emphasis on MRW waste)
IV. Spills
V. Industrial Waste Water Management
VI. Joint inspection(s) with the Training Coordinator as a lead on an Ecology hazardous waste
inspection
VII. Joint inspection(s) with the Training Coordinator as backup on a Local Source Control
inspection
2. New Hire Mentoring, Joint Site Visits, Orientation Training
• The LSC Program Training Coordinator will develop an on -going training plan, course list and
materials. All training materials will be available on the LSC SharePoint site.
• Ecology's LSC Program Training Coordinator will orient the new hire by providing them with
technical and program - specific information.
• Each new Specialist will be assigned a mentor by the LSC Program Training Coordinator. The
Coordinator will select mentors from the pool of experienced, available LSCS and / or Ecology
staff. The mentor will conduct at least three site visits with the newly hired Specialist.
• Some Specialists may require more or less mentoring than others. If the mentor feels more than
three joint site visits are warranted, the mentor will contact the Training Coordinator to discuss
next steps.
• The Training Coordinator will work to ensure that the Specialist is fully capable of performing the
duties of a Local Source Control Specialist without additional assistance.
State of Washington, Department of Ecology
IAA No.
3. Topics for New Hire Orientation Training
Topics include, but are not limited to:
I. Share Point Orientation
II. Checklist & Database Basics
III. LSCS Training Program
IV. Quarterly Training Team Identification & Participation
V. Mentoring
VI. Customer Service
VII. Networking
B. All Specialists
1. Orientation, Attendance & Participation
Ecology will present an orientation class that precedes the first in- person group meeting of the
biennium, and subsequently thereafter to every new Local Source Control Specialist within six
months of hire. Orientation sessions will be held within semi - annual periods where we have new
Specialists. The location will be Ecology's Northwest Regional Office or other suitable location
determined by the Training Coordinator.
• Each Specialist is required to attend new orientation at least once, as well as all subsequent
monthly webinars and quarterly trainings throughout the biennium.
• All Specialists must be an active group participant in the planning and logistics of at least one
quarterly training, with each group of four to six Specialists assisted by the NWRO LSC Training
Coordinator and an assistant. Approximately ten hours of Specialist time should be allotted for
this activity, equivalent to four site visits.
• Each experienced Specialist will at some time be called upon to mentor a new Specialist.
Approximately 30 hours should be allotted for Mentoring activity. This will be equivalent to twelve
site visits.
2. All Specialists Ongoing Training
The LSC Program Training Coordinator will develop an on -going training plan, course list and
materials, with input from the Specialists. All training materials will be available on the LSC
SharePoint site.
Course content will be presented in- person or on -line, depending upon available resources.
Topics will be presented to all Specialists, and will be mandatory for new Specialists during their first
six months of hire, and thereafter to each Specialist once every four to six years or more frequently
by Specialist election.
Topics include but are not limited to:
I. Storm Water Inspections
ll. Hazardous Waste (40 CFR/WAC 173 -303) (emphasis on Designation and waste codes)
III. Solid Waste (with an emphasis on MRW waste)
IV. Spills
V. Industrial Waste Water Management
State of Washington, Department of Ecology
IAA No.
3. Quarterly Trainings
One -day, four to five hour in- person training sessions, with content developed by a designated group
of four to six Local Source Control Specialists who will plan the agenda, topics, and procure guest
speakers of their choice. Ecology will provide support for these efforts, the meeting space and lunch
at its Northwest Regional Office in Bellevue, or other suitable central location determined by the
Training Coordinator.
4. Monthly Call -in Business & Topic Meetings
In each of the months between quarterly trainings, Ecology will sponsor hour -long call -in meetings on
the second Wednesday of each month, 9:00 to 10:00 am and will include but are not limited to:
• Guest speaker(s)
• LSC Specialists are also encouraged to present to their colleagues
• Discussion /updates of cover program business and administration
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