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HomeMy WebLinkAboutDAQ-2024-0108661 DAQC-990-24 Site ID 10122 (B4) MEMORANDUM TO: STACK TEST FILE – BIG WEST OIL, LLC THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Robert Sirrine, Environmental Scientist DATE: October 1, 2024 SUBJECT: Source: MSCC (FCCU) Location: 333 West Center Street, North Salt Lake, Davis County, Utah Contact: Brady Miller, 385-324-1275 Tester: Erthwrks, Inc. Luke Morrison – 512-962-7661 FRS ID #: UT0000004901100008 AO #: DAQE-AN101220081-24, dated May 6, 2024 Subject: Review of Pretest Protocol Dated September 20, 2024 On September 26, 2024, Utah Division of Air Quality (DAQ) received a pretest protocol for the Milli-Second Catalytic Cracking Process (FCCU) vent operating at the Big West Oil (BWO) refinery located in North Salt Lake, Utah. Testing will be performed November 20-21, 2024, to determine HCN and NH3 emission factors found in Condition II.B.3.f, and 40 CFR 63, Subpart UUU. PROTOCOL CONDITIONS: 1. RM 1 used to determine sample velocity traverses: OK 2. RM 2 used to determine stack gas velocity and volumetric flow rates: OK 3. RM 3A used to determine dilution concentrations of exhaust oxygen: OK 4. RM 4 used to determine stack gas moisture content: OK 5. ASTM D6348-03 used to determine HCN and NH3 emissions: OK DEVIATIONS: No deviations were noted. CONCLUSION: The protocol appears acceptable. The Source AO does not indicate that 40 CFR 63, Subpart UUU is applicable which requires a one-time HCN test on applicable FCCUs. The source is testing for HCN because specific parts of Subpart UUU applies to other BWO monitoring requirements. The NH3 emission factor is used in some of the emission inventory calculations, so BWO has decided to test for a new emissions factor. RECOMMENDATION: Send protocol review and test date confirmation notice. ATTACHMENTS: Stack testing protocol dated September 20, 2024. .,,.dh_4" BigWest Oil 333 W. Center Street . North Salt Lake Utah 84054 . 801.296.7700 . www.bigwestoil.com September 20,2024 CERTIFIED MAIL RETURN RECEIPT NO.9589 0710 5270 1318 3715 06 Rob Leishman Division of Air Quality Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144820 Salt Lake city, Utah 84114-4820 RE: 4Q2024 MSCC Performance Test Plan - Big West Oil DEPAT]TMENT OF ENVIHONMEN]AL QUALITY sEP 2 4 2024 DIVISION OF AIR OUALITY Dear Mr. Leishman, Enclosed is the site-specific test plan for the performance test that Erthwrks will be conducting on Big West Oil's MSCC Regenerator Vent during the week of November 21,2024. Erthwrks will be conducting this MSCC performance test in accordance with the requirements found in 40 CFR 63.1571(a)(6xii). During this test, NH: emissions will also be analyzed using the same method. The purpose of this MSCC performance test is to confirm the prior HCN emissions testing results required by 40 CFR 63 Subpart UUU, $63.1571(ax6xii). Concurrently, this test will also be determining a site-specific NH: emission factor for more accurate emission program reporting. For questions regarding this performance test plan, pleasecontactBrady Miller at (385) 324- 1275. Enclosure: Erthwrks MSCC Performance Test Plan Brady Miller Environmental Engineer A'R EM'SS'ONS TESflNG FOR 'NDUSIRY Emission Testing Protocol Big w.rfbiL LLC at the North Salt Lake Refinery Hydrogen Cyanide and Ammonia Determinotion on the MSCC Regenerator Vent subject to Permit No. DAQE-ANIO 1220081-24 40 CFR 63, Subpart UUU Test Dates: November 21, 2024 Erthwrks Project No. 9855 +* CARB DIT'ANIMINT OF ENVIHONMLNIAL QUALITY SEP 2 4 202t1 DIVISION OF AIR OUNLITY prepored for STAE Endorsement Page This protocol was developed in accordance with the requirements designated in the applicable regulatory permit(s) and or regulatory rules. To the best of my knowledge the techniques, instrumentation, and calculations presented in this protocol will serve to complete the test campaign requ irements accurately and effi c iently. Erthwrks,Inc. Name: Title Signature: Name: Title Signature: This protocol has been reviewed for accuracy and completeness. The actions presented in this protocol are, to the best of my knowledge, an accurate representation of the necessary work scope needed to successfully complete the requirements of the test campaign. Erthwrks operates in conformance with the requirements of ASTM D7036-04 Standard Practice for Competence of Air Emission Testing Bodies. Erthwrks,Inc. Luke Morrison John Wood errm!Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 219/20/2024], 2ofL6 I .0 [NTRODUCTrON...... ...................... 4 l.l Contact Information/On-Site Personnel ............4 2.0 FACILTTY DESCRIPTION........... .......................5 3.0 SAMPLINC AND ANALYTICAL PROCEDURES........... ....................5 3.1 Gaseous Sampling -Oz and CO2............ ............5 3.2 Direct Interface FTIR for HCNNH3 ................7 3.3 CO Monitoring............ ....................7 3.4 Discussion of methodology variations or operational variances .............7 4.0 Ceneral Work Sequence, Site Hazards and Mitigation, and Tentative Schedule ....... 8 4.1 Ceneral/ Overall Safety Precautions and Risk Mitigation.. ....................8 4.2 Tentative Schedule.... .......................9 Appendix A............... .........10 Example SOR and Calculations................ .............10 List of Tables Table I : Test Matrix .......................5 Table 2: Tentative Work Schedule... .................9 erfhwrk3 Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 219/20/2024) Erthwrks, Inc. has been contracted to provide air emission testing services for Big West Oil (BWO) at the North Salt Lake Refinery located in North Salt Lake, UT. This testing program will be conducted on the Millisecond-Catalytic Cracking Process (MSCC) for the determination of Hydrogen Cyanide (HCN). The purpose of this activity is to confirm the prior emission testing results required by the 40 CFR 63 Subpart UUU, $63.1571(aX6)(ii). The testing is scheduled for November 21,2024. In addition, concurrent testing will be conducted utilizing the same methodology for the determination of a site-specific ammonia (NH3) emission factor for more accurate emission program reporting. Big West Oil, LLC Brady Miller Env ironmental Engineer 333 W Center St. North Salt Lake, UT 84054 385-324-1275 brady.m i I ler@bigwestoil.com Erthwrks,Inc. Luke Morrison Project Manager P.O. Box 150549 Austin, TX787l5 512-962-7661 office 888-573-9994 fax Lmo rrison@erthwrks.com Erthwrks,Inc. John Wood Technical Director P.O. Box 150549 Austin, TX 78715 512-585-1685 office 888-573-9994 fax jwood@erthwrks.com Facility Location: Big West Oil, LLC North Salt Lake Refinery 333 W Center St North Salt Lake, UT 84054 erfhwa Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 2 (9/20/2024], 4of15 Table l: Test Matrix 40 CFR 63 Subpart UUU HCN Mass Rate / Emission Factor EPA Method 1,2,3A ASTM D6348-03'i 3, l-hour Runs NHi Mass Rate / Emission Factor EPA Method 1,2,3A ASTM D6348-03*3, l-hourRuns *ln accordance with 563. I 57 I (a)(6)(iil(B), ASTM D6348-03 Sections A I -A8 will be followed, Annex A5 (analyte spiking technique) will be determinedfor each target analyte, and the %R will be between 70'% and I 30% lo validate the tesling results. Slack moisture content will be determinedfrom ASTIVI D6348 for the exhaust flow / mass emission rate calculation. Located in North Salt Lake. Utah, the facility is a high conversion refinery operated by Big West Oil LLC. a rvholly orvned subsidiary of FJ Management lrrc. The lacility has a total capacity of 35.000 barrels per day and refines a combination of Utah. Wyorning and Canadian crude oils into high-quality motor firels and other specialty chernicals. Big West Oil products meet or exceed government standards fbr clean transportation firels. as r,vell as cLlstomer needs fbr engine perfbrmance and cold flow qualities. For all gaseous sampling, Erthwrks will insert a stainless-steel probe, of sufficient length to reach all sampling points, into a sampling port that is located on the stack in accordance with EPA Method l. The sample is extracted through the probe, a heated Teflon sampling line, to a heating filter. The sample then enters a minimum contact sample conditioner that cools and removes moisture from the gas matrix prior to entering the Erthwrks sampling manifold. For this project, the following Reference Methods will be used as applicable: o EPA Method 3,A for the determination of Oz and COz concentrationo EPA Method l -4 for volumetric flow rate Erthwrks will follow all quality assurance and quality control procedures as defined in US EPA 40 CFR 60 Appendix A. The Calibration Error (CE) Test will be conducted as specified in EPA Method 7E $8.2.3. [n accordance with this requirement, athree-point analyzer calibration error test will be conducted prior to sampling. The CE test will be conducted by introducing the low, mid, and high-levelcalibration gasses (as defined in EPA Method 7E $3.3.1-3) sequentially and the response will be recorded. The results of the CE test are acceptable if the calculated calibration error is within *2.0yo of calibration span (or < 0.5 ppmv). Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 2 (9/20/2024\ 5of15 erfhrtrrQ The Initial System Bias and System Calibration Error Check will be conducted in accordance with EPA Method 7E $8.2.5. The upscale calibration gas will be introduced at the probe upstream of all sample system components and the response will be recorded. The procedure will be repeated with the low-level gas and the response will be recorded. The sample system response time will also be recorded. This specification is acceptable if the calculated values of the system calibration error check are within *5.lyo of the calibration span value (or <0.5 ppmv). After each compliance test run, the sample system bias check will be conducted to validate the run data. The low-level and upscale drift will be calculated using Equation 7E-4. The run data is valid if the calculated drift is within +3.UYo of the calibration span value (or <0.5 ppmv). After each test run, the effluent gas concentration will be calculated as specified in EPA Method 7E $12.6. The arithmetic average of all valid concentration values willbe adjusted for bias using equation 7E-5B. The figure below details the Erthwrks Gaseous Sampling System. S.mpl. Prcb. s.mpl. sy.t m ll.. c.llbntlon Lln. h..t d rampl. lln. C.llbEtlon Gaaaaa g .9aEa EaI rotomatar rctomatar Figure 1: Example Erthwrks Gaseous Sampling System Diagram erfrtft Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 2 .9120/2024l. 6of16 Erthwrks will follow all quality assurance and sampling procedures as outlined in ASTM-D6348- 03. Three l-hour sampling runs will be used to quantify average concentrations of HCN and NH3. A series of pre-test preparations and evaluations will be conducted on site priorto sampling as outlined in ASTM-D6348-03. These procedures include determining a minimum detection limit (MDL), determining the sample system response time, developing a spectral background, and the introduction of a calibration transfer standard (CTS) to veriff sample cell pathlength. The calibration transfer standard will be introduced directly to the FTIR sampling cell, and the results will be recorded. The measured response of the FTIR will be within 5% of the certificate value. Erthwrks will use an EPA Protocol I gas cylinder containing ethylene at approximately 100 ppm as the CTS. Upon completion of all required pre-test measures, Erthwrks will perform a dynamic spike. A pollutant of known concentration will be introduced to the sample system at the tip of the probe and will be mixed with the effluent gas at a ratio no greater than l0: l. A flowmeter and tracer gas (SF6) will be used to measure the spiking rate. A recovery percentage between 70% -l30Yowill be achieved before sampling commences. During sampling Erthwrks will utilize a scanning rate of 64 scan/min and an averaging rate of 60 seconds. A spectrum will then be generated once every 60 seconds, and the resulting concentrations will be added to the cumulative data file. All spectra and raw interferograms will be appropriately named and saved. In accordance with $63.1571(a)(6XiiXB), ASTM D6348-03 Sections Al-A8 will be followed, Annex 45 (analyte spiking technique) will be determined for each target analyte, and the %R will be between 70oh and 130% to validate the testing results. CO monitoring will be conducted Big West Oil will provide the CO an appendix in the final report. in accordance with 40 CFR 63 Subpart UUU, table data from their CEMS system. This data will be 12, item2. included in This emission variances. program is expected to be conducted no sampling or operational errml Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 2 (9/20/20241 7of16 Erthwrks works diligently to eliminate and minimize potential hazards as they apply to our equipment and the test procedures used during the field campaign. A list of safety risk mitigation measures to be employed by the Erthwrks teams during the field campaign is summarized in subsections below. These mitigation measures range from general items applicable to the overall field campaign as well as specific measures associated with the mobile lab/electrical equipment as well as the field execution. The minimum PPE requirements will include hard hats, safety glasses with side shields, steel-toed safety shoes, hearing protection, fire resistant clothing, fall protection, and a personal HzS monitor. The following hazards are expected during the field test campaign: Working at heights. Using and transporting compressed gases. Electrical hazards from high voltage planVgenerator power sources and operation of electrical equipment inside and outside the test van. Heat stress and fatigue. Fire hazards associated with non-intrinsically safe equipment. Hot surfaces (stacks and sample ports ryill be at high temperatures). Tripping hazards present around test van (multiple power cords connected to test van and sample line) and on sampling platform. . All Erthwrks personnel attend annual basic plus mandatory trainings, including all required site-specific training and background checks. o All field team members will be equipped with proper PPE compliant with BWO procedures. o Per Erthwrks requirements, a Job Safety Analysis (JSA) form will be prepared by all members of the field staff prior to commencement of the field campaign. Each day will begin with a TBT conducted by the field team lead discussing potential hazards, and evacuation routes specific to that day's location within BWO. No work will begin until a proper permit has been issued and all necessary BWO Operations staff has been informed. o The mobile lab will be parked at the nearest allowable/safest location below the stack area. A field technician will ascend the stack to the sampling platform and use a rope to haul a heated sampling line to the platform. The sample line will be secured to the platform by use of rope or suitable temporary fasteners. All elevated work, including work on the sample platform, will be done with proper harnessing and fallprotection equipment (if required) and approved by BWO. a o a a o o a Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 2 (9/20/2024\ 8of16 erfhvvrQ o Technicians working on the stack platform will have appropriate heat resistant gloves when removing sampling port plugs and when handling hot sampling probes. o All hand tools will be equipped with lanyards and stored in tool bags to prevent dropped objects. o The sampling line will be secured to the platform and at other point(s) on the unit to minimize swinging. o Once tests at a particular stack are completed, a field technician will ascend to the stack platform and carefully lower the heated sample line. The power supply will be unhooked from the lab and the area cleared (with good housekeeping). Operations will be informed, and the lab will be driven away from the area and parked in an approved area of the plant or at the next testing location. o Setup and teardown procedures will involve all Field Team staff Table 2: Tentative Work Schedule MSCC Emission Testing HCN and NH3November 21,2024 Erthwrks Project No. 9855 -Big West Oil North Salt Lake Refinery MSCC HCN and NH3 Emission Testing -Version 2 (9/20/20241 10 of 16 Erthwrks Summary of Results Date: Client: Facility: Unit lD: Erthwrks Tech: 6t4t2024 Run Number Date Run Start Time Run End Time Run 1 Run 2 Run 3 6t4t2024 6t4t2024 6t412024 17:23 18:40 19:53 18:23 19:40 20:53 NSP Gas Flow (MSCFD) NSP GAS GC (molecular weight) NSP GAS GC (Btu/lb) LHV NSP GAS GC (Btu/lb) HHV NSP GAS LHV (Btu/sc0 NSP GAS HHV (Btu/ScO NSP Gas Fd (dscf/MMBtu) 114',t 1157 1 139 18.66 18.67 18.70 19905 19872 19850 22017 21981 21957 979 978 978 1082 1082 1092 8691 8691 8691 1145.7 18.68 19875.7 21985.0 978.3 1085.3 8691.0 PSA Gas Flow (MSCFD) PSA GAS GC (molecular weight) PSA GAS GC (Btu/lb) LHV PSA GAS GC (Btu/lb) HHV PSA GAS LHV (Btu/sc0 PSA GAS HHV (Btu/scf) PSA Gas Fd (dscf/MMBtu) 5694.0 5663.0 5550.0 21.7 21.8 21.7 4303 0 4304.0 4386.04895.0 4889 0 4985.0 246.0 247.0 250.0 280.0 280.0 284.08719 8719 8719 5635.7 21 .7'l 4331.0 4923.0 247.7 281.3 8719 NSP Gas Duty LHV NSP Gas Duty HHV PSA Gas Duty LHV PSA Gas Duty HHV Total Duty LHV Total Duty HHV Combined Fuel Fd (dscf/MMBtu) 'NsP fraction 0.17 PsA fraction o.83 o/o ol Max Duty LHV Max Duty 125.6 MMBtU/hr % of Max Dutv HHV Max DUN 139.6 MMBtU/hr 46.5 47.2 46.4 51.5 52.2 51.3 58.5 58.2 57.9 66.5 66.2 65 8 105.0 105.4 104.3 1 18.0 1 18.3 ',117 .1 8714 8714 87',t4 84% 84% 83% 85Yo 85% 84Yo 46.7 51.7 58.2 66.2 104.9 117.8 8714 83.5% 84.4% NOx (ppmvd) NH3 (ppmvd) COz (%vd) CO (ppmvd) Oz(%vd) Moisture (B*) Exhaust Flow (scf/h0 13.91 12.37 12.25 9 07 8.1 8 9.64 12.23 12.22 12.10 0.60 0.24 0.41 6.42 6 33 6.59 01475 0.1666 0.1608 1 .62E+06 1.56E+06 1 .61 E+06 't2.85 8.96 12.19 0.42 6.45 0.1583 1.60E+06 NOx (ppmvd @7 o/oO2) NHr (ppmvd @7 o/oOz\ 13.36 11.81 1't.90 8.70 7.81 9.36 12.35 8.62 NOx (lb/scf) NH3 (lb/scf1 1.66E-06 1.48E-06 1.46E-064.01E-07 3.62E-07 4.26E-07 1.53E-06 3.96E-07 NOx (lb/MMBtu HHV) NH: (lb/MMBtu HHV) 0.021 0.018 0.019 0.00s 0.005 0.005 0.0193 0.0050 NOx (lb/hr) NH3 (tb/ho 2.69 2.30 2.360.65 0.56 0.69 2.45 0.63 of '16 Erthwrks QAQC Example Calculations Example Calculations for Pollutant :02 os, = c,L; c, * roo ACE = O,460/o CDi. = 10.01 Cv = 9.92 CS= 20.00 o/o o/o o/o sn,= Sffei.. * roo SB; = -0.550/o CS= 20.00 Cs = 9.90 Co'. = 10.01 o/o o/o o/o D = ABSISBT - SBi I SBi = -0.550/o SBr - -0.680/o D=O.l3o/o ccu. = (caue-c") #%; Cc"" = 6.42 Ca,8= 6.42 Co = 0.07 Cne = 9.92 Cu = 9.88 o/o o/o o/o o/o Variahle:Descrintion: co Cor. Coi. CM CMA CS cs cv SBr SBI Average ofthe pre- and post-run system cal bias responses from zero gas, ppmv. Average unadjusted gas concentration for test run, ppmv. Measured concentration of the cal gas when introduced in direct mode, ppmv. Average ofthe pre- and post-run system cal bias responses from the upscale gas, ppmv. Actual concentration ofthe upscale calibration gas, ppmv. Calibration span, ppmv. Measured concentration ofthe cal gas when introduced in the system cal mode, ppmv. Manufacturer certified concentration of calibration gas, ppmv. Post-run system bias, percent ofcalibration span. Pre-run system bias, percent ofcalibration span. Erthwrks Example Calculations Nomenclature MGV Molar gas volume, volume of gas at standard conditions, scf/lbmol V Volume, ft3 n Moles, lbmol Fd Fuel F Factor, scf/MMBtu %O2d Oxygen concentration measured on a dry basis, % FH Fuel Heating Value (MMBtu/hr) Hp Engine horse power during test, hp Constants R 10.7316 Universal gas constant, ft3 psi / R lbmol Ts 527.67 Standard Temperature, R p" 14.696 Standard Pressure, psi MW1ro, 46.0055 Molecular Weight of NOx, lb/lbmol MWco 28.0104 MolecularWeightof CO, lb/lbmol MWsoz 64.0588 Molecular Weight of SO2, lb/lbmol MWvoc 44.0962 Molecular Weight of VOC as propane, lb/lbmol Fd 8675 Fuel F Factor for Natural Gas, scf/MMBtu Conv,oo 453.6 Number of grams in one pound Molar gas volume (MGV) calculation at standard conditions (ldeal Gas Law) MGV R'T" Psn \NhereT= 293.15 K P = 760 mmHgft= 62.3637 L mmHg K mol V n Molar Gas Volume 62.3637 . 293.15 760 gmol MGV 1 0.7316 ' 527 .67 n 385.325 14.696 MGV scf lbmol Emission Concentration, Crq,, lb/scf (For NOx, Run 1) C*ot PPMN6, ' MW1,o,- 106MGV _ 13.91 ' 46.0055 r 385.325 1.66E-06 24.055 10-6CHo, tb scfCro, EXAN/I PLE Erthwrks Example Calculations Emission Rate Calculation, E11ry1uetu1, (For NOx, Run 1) E-L(tbfrrMBtu) E116rul,tatr1 = L(IbiilMBfuI trE*vNOx I d 1.66E-06' 8710 r tb0.026 20.9 2O9 - '/"Ozd 9.08 MW * 1.556*10^-7 46.006 * 1.556',10^-7 20.9 Emission Rate Calculation, Eqrwrnp (For NOx, Run 1) MMBtu E1pn,) = Nox PPmd * Qstd (dscfin) * E11orrr4 = 13.914 '27030.448' EXAN/I PLE Erthwrks Example Calculations Nomenclature Cco Carbon Monoxide concentration measured on a dry basis, ppmv C"o, NOx concentration measured on a dry basis, ppmv Cvoc VOC concentration measured on a dry basis, ppmv %O2d Oxygen concentration measured on a dry basis, % Emission Concentrations Corrected to 15% 02 (For NOx, Run 1) Nox = cro,. *n=-ET??20.9 - %O2d Nox = 13e1 -j3## Nox = 6.es ,lS:[9 EXAN/I PLE Erthwrks Method 1-4 Example Calculations Dry Molecular Weight of Stack Gas, M6 Mo = 0.440 (o/oCO2) + 0.320 (%O2) + 0.280 (%N2 + YoCO) Molecular Weight of Stack Gas, M" M. = Mo (1 - Bws) + 18.0 * Bws Mo = Molecular weight of stack gas, dry Average Stack Gas Velocity, v" v. = Kp * Cp " Ap("un)"' t 1t2ls(abs) P""M. (lb/lb-molX"Hg 1/2 ('R)(inH2O) 0.84 Ts(abs) = Avg Stack Temp ('F) + 460 P, = Stack Pressure (Pbar + Pg) ("Hg) M" = MW of Stack Gas (see above) + 0.32 * 6.420/o 0.28 . 81.35% 0.8688 "( 962.3 / 28.96 I 28.41 )1t2 . 28.96 Md= Md= 0.44 * 12.23o/o 30.2{36 Eq.3-1 Eq.2-G Eq.2'7 Eq.2-8 Ms M" (Method 3) Bws = Water vapor in gas stream (Method 4) = 30.21 * (1-0.149 ) + 19.0 .0.149 = 28.41 Vs= vc= Kp = 85.49 fUsec Cp = Pitot Coefficient 85.49 . 0.84 . 67.467 Average Stack Gas Dry Volumetric Flow Rate, Q Q = 3600. (1 - Bws) * v" * A. (Trro ) ( P" ) (Ts(aos))(P.to) Ttto = 528 "R P'to = 29'92 "H9 o- Q= 3600 ( 1 - 0.148 \ 67.467 * 14.75 *( 528.0,.,=-OEXAN/I PLE 962.25 I 29.92)