Greg Bannon demolishes the case for Kimba/Hawker nuclear waste dump, in a trenchant Submission
This is a National issue and a National problem. Small, remote communities, whether at Kimba, the Flinders Ranges or anywhere else, should never be expected to make the decision alone to accept the toxic by-products of one industry’s lifetime production.
Nuclear Medicine: It was impressed on the community that a primary reason for the NRWMF is the need to dispose of Australia’s radioactive medical waste. DIIS is the only official source of information, some of which implies that procedures such as CAT scans, X-Rays, and cancer treatments require the use of radioactive isotopes. Plain scans, X-Rays and a vast majority of cancer treatments do not use such isotopes.
It is a genuine and valid concern that ILRW may become stranded at this facility for any number of reasons.
ILRW has been the “elephant in the room” from the Day 1 of this process. The emphasis has been on Low Level Radioactive Waste and, even today, people in our community say “it is a low level waste dump”.
Submission from: Greg Bannon, Resident of Quorn, Flinders Ranges Council Region, Barndioota Site to SENATE ECONOMICS REFERENCES INQUIRY – National Radioactive Waste Management Facility (Submission no. 85) 13 attachments
I have connections to this region that go back to the late 1950’s. My family first visited Wilpena Pound on a holiday in 1958. The following year, on a return visit to Wilpena with some overseas friends, my younger brother became lost and died. He is buried at Hawker. I worked on Partacoona and Warrakimbo Stations in the 1960’s. Warrakimbo shares a boundary with Wallerberdina. Later, I worked for a corporate farming company in Esperance, WA, for over 30 years. During that time I made many visits to this region.
My partner and I purchased land on the outskirts of Quorn in 1999 and came here in 2003 to renovate a building, live and retire. We chose the region because of a long affinity to it, a love of the landscape, a connection to the community and friends who live here. We have tried to contribute by involving ourselves in community life and activities.
It was a great disappointment to hear that the region had been nominated to accept a radioactive waste facility. We had never considered this as a possibility. This proposal is completely at odds with everything that is promoted for our region. We believe that on many grounds, set out below, it should never have been nominated, let alone made it on to the short-list.
Addressing the Terms of Reference:
- a) Financial compensation offered to applicants for the acquisition of land under the Guidelines.
There is considerably more to the issue of site selection than the compensation offered to the successful nominator. The process to select a site for the National Radioactive Waste Management Facility (NRWMF) has been problematic since this current search was announced by Senator Ian McFarlane in March, 2015. All previous attempts to establish a facility have met with resistance from local communities and/or State Governments and have not been successful. Legislation was enacted in a number of States to prohibit the establishment of certain types of nuclear waste storage facilities in direct response to the Federal Government’s actions.
The Department of Industry, Innovation and Science (DIIS) nomination process started in March, 2015, with an invitation to landholders to offer land for the NRWMF. This was claimed to be “international best practice”, however, there was no requirement for the nominator to consult or inform his community, or even his nearest neighbours. That would have been “best practice”.
Housing a radioactive waste management facility on a pastoral property is a major departure from the accepted land use for the area and contrary to conditions of operating a pastoral lease. It would seem a serious omission of compliance has been committed in proposing this facility without consulting State land use regulators. Once established, the facility will be actively accepting low level radioactive waste (LLRW) for 100 years and will require oversight and management for a further 300. Co-located on the same site will be an unspecified amount* of intermediate level radioactive waste (ILRW), to be temporarily stored for an unspecified time*.
(*unspecified amount – ANSTO is planning increased production of radioactive isotopes for medical use to potentially supply an international market. Increased production must increase waste.
*unspecified time – “Temporary” has been defined variously as from 20, 30, 40, even up to 100 years .)
ILRW can only be stored at this site on a temporary basis. DIIS has stated that for permanent disposal it requires deep burial in geologically stable conditions – no such site exists in Australia today and there is currently no plan to develop one.
It is not clear how widely the invitation to submit nominations was advertised. Site nominations closed on the 5th May, 2015. 28 were received, 25 were assessed and a short list of 6 was announced by Minister Frydenberg on 13th November, 2015. One of three in SA was named as Barndioota, in the Flinders Ranges region. This was the first time I became aware that my region was being assessed to accept radioactive waste. Research was required to find where “Barndioota” actually was.
It is not clear why the name “Barndioota” was used as the location of the site instead of by the well-known property name “Wallerberdina”. “Barndioota” was not a name in regular local use and very few people knew where it was. Only a landowner paying rates in that section of the Flinders Ranges Council (FRC) region would know of the “Hundred of Barndioota”. In fact, the area of Wallerberdina that is currently being assessed for the NRWMF is in the neighbouring “Hundred of Cotabena”. This area is classified as “Out of Districts”, outside local government boundaries, and under the jurisdiction of the Outback Communities Authority.
Prior to the November 2015 announcement, nearly nine months after the call for nominations, very few of the community if any, were aware that Barndioota/Wallerberdina had been nominated to house radioactive waste. Not even the Flinders Ranges Council was informed of the nomination.
(See attachment #1 – The Flinders Ranges Council Community Newsletter, November, 2015)
By contrast, the nominator was fully informed on the entire history and scope of the project. A partner in the lease of Wallerberdina for a relatively short time, he does not live on the property. He is a former South Australian Federal Senator and served on three Senate Select Committees related to this industry – Dangers of Radioactive Waste, 23/03/95 to 24/04/96 (Chair from 30/03/95); Uranium Mining and Milling, 08/05/96 to 15/05/97 (Chair from 23/05/96); and Lucas Heights Reactor, 17/08/00 to 24/05/01.
- b) How the need for “broad community support” has played and will continue to play a part in the process, including:
- i) Definition of “broad community support”.
DIIS contracted Orima Research to assess community support and produce a report. It is a large document, of over 200 pages, containing all the charts, bar-graphs, tables, questionnaires, responses, summaries etc. from each of the six shortlisted sites. There is a lot of repeated information and it is confusing for a layman to decipher.
(See attachment #2 – Department of Industry, Innovation & Science, National Radioactive Waste Management Facility, Community Sentiment Survey, Wave 2 Report of Findings, April 2016)
The document is difficult to read and understand. It contains many unsubstantiated statements which are vague or even misleading. For a seemingly thorough and comprehensive report it lacks academic rigour. Some examples (by no means all) are listed below:
Ø P88, para 1 – (a) “general population survey” & (b) “near neighbour survey” – No clear explanation of the reason to separate these categories. (It has now become clear that consideration has been given to altering boundaries defining who is eligible to take part in a final vote. In Kimba, there have been different definitions of “near neighbour”).
Ø P92, Pilot, para 1 – “….non-interlocking target of 50% of sample” – This sounds like gobbledegook. There is no explanation of what the term “non-interlocking” means.
Ø P92, Pilot, para 2 – “Generally speaking the questionnaire worked well during the pilot” – There is no statement that pilot responses were not included in the main survey. There is nothing to say that people interviewed in the Pilot were not re-interviewed in the main survey.
Ø P94, Main Survey Sample Method, para 2 – “A minimum number of call-backs were made to all households, and in smaller communities….the number of call-backs was greater” – What number is “minimum” and what is “greater”? These should be quantified or the statement is meaningless.
Ø P108, Field Issues, para 2 – “…significant difficulties were encountered.” – This language is simply too vague for a statistical document.
P109, Sample Frame Limitations, para 4 – “despite the high quality of the SamplePages listings, it is evident that they do not include all households in the target area.” – Phone numbers sourced from “SamplePages” were primarily composed of landline numbers. Many local people relying only on their mobile service would not have had an opportunity to take part in the survey.
Ø P118, Q 12 – “Do you strongly support, somewhat support, somewhat oppose or strongly oppose….continuing with the process….” – Tantamount to “push polling”. There may be a tendency for respondents to opt for the first option, leading to a response bias.
Ø P119, Q 13 – “Why have you not formed an opinion on this topic? Is it because….” – this is tantamount to prompting.
Ø P119, Q 14 – “Would you be willing or not willing to see your community continue to the next stage….or do you not mind either way?” – More response bias. With no pre-amble to describe the next stage, the respondent is not fully informed of what they are responding to. It would be natural for a respondent to consent to hear more information.
Ø P119, Q 15 & 16 – These ask about “…concerns or negative impacts….for….your community from hosting the NRWMF?” and “…benefits….for….your community from hosting the NRWMF?” – The survey claimed to “ascertain support for continuing to the next phase of the public consultation process”. These questions were premature, not due until the end of the next phase, asked of very small sample and in the context of no information having been provided.
Ø P110 – “In the case of all the community sentiment surveys, the response rates have been significantly higher than industry norms. Moreover, in several of the communities – Cortlinye, Pinkawillinie, Barndioota and Oman Ama – the response rates have been exceptionally high across all the surveys. These unusually high response rates can probably be attributed to the saliency of the issue in these communities” – The word “significant” not quantified. What are the “industry norms”? “Probably be attributed to” is not rigorous or scientific. Is this an attempt to exaggerate credibility for the survey?
Orima Research determined that 65% of the respondents to the Barndioota/Wallerberdina survey did not oppose the process moving into the second phase of consultation. This response has been publicly misrepresented many times to give the impression that the community has agreed to support the facility. The community has never been formally asked whether it wants it or not.
(#2- p100 Note: The respondents represent only 11% of the population – i.e. 146/1331)
There were two independent attempts to determine the level of support within the community, by the community.
- a) A petition against the proposal was circulated from Hawker in 2016. It attracted over 800 signatures of which 91 were from Hawker (54% of the voting population), and 251 were from Quorn (42%). This indicates of a lack of broad-based community support.
(See attachment #3 – Dr. S Andersson, MBBS, Petition Notes)
- b) Flinders Local Action Group conducted a survey in 2016, asking the question “Do you want a NRWMF established at Wallerberdina Station/Barndioota – Yes, Undecided or No?” It was conducted in two parts. The first collected votes outside the Quorn Town Hall and at the annual Quorn Show. The second attempted to distribute survey forms through Australia Post’s Unaddressed Mail Service. Forms distributed through Quorn Post Office were only delivered to boxes that accepted “junk mail”.
By contrast, all DIIS material and newsletters are delivered without restriction to every mail bag and letterbox in the district.
The two parts of the survey returned “No” votes of 92% and 79% respectively.
(See attachment #4 – Flinders Local Action Group, Community Survey Report, December 2016)
- ii) How “broad community support” has been or will be determined for each stage of the process.
In the Adelaide Advertiser, 6/09/2017, a senior official from DIIS wrote, “…the Federal Government is not pushing for a state-of-the-art National Radioactive Waste Management Facility in SA”. If not “pushing”, the actions below demonstrate a very concentrated effort in South Australia from DIIS.
(See attachment: #5 – Clipping from The Advertiser)
For eighteen months or more, our community has had weekly attendance in the towns of Hawker and Quorn by staff from DIIS and ANSTO, to allow people to ask questions and gain information.
There have been a number of public meetings and a number of speakers addressing different issues related to promoting the need for a NRWMF.
DIIS, ANSTO and AusIndustry staff have manned displays, with hand-outs for children, at two successive Quorn Shows and the inaugural Hawker Community Fest.
A representative of AusIndustry re-located his family to Hawker for a period of time in 2017 to assist with issues related to the Community Benefit Package grants.
The DIIS and ANSTO message has focussed on the use of “state-of-the-art, international best practice”, safety of all procedures and how benign the waste material will be. The emphasis has been on alleviating concerns and accentuating the benefits to the community.
There has never been, despite requests from some quarters, a public forum giving the community an open opportunity to discuss and analyse the strengths, weaknesses, opportunities and threats.
The Barndioota Consultative Committee (BCC) was formed, meeting regularly. It is not clear what role this committee performs. It has no decision making authority.
- i) There are restrictions on what Committee Members are allowed to disclose from meetings.
- ii) At this time, April 2018, no guidelines or protocols have been set to allow members of the community to attend these meetings as observers. On two occasions, orderly community members wanting to listen and observe have been ejected
iii) The meeting does not publish minutes, only notes. Notes were previously published and posted out but the frequency has dropped off. They can be accessed on-line, but at 22/03/18 the December ones are still not available.
A Community Liaison Officer was appointed.
Regular newsletters appeared in all our letterboxes and mail bags, also on line. By contrast, strictly enforced postal regulations in Quorn have restricted bulk posting of independent information to the community. It will only be delivered to letter boxes that accept “junk mail”.
A delegation of four dignitaries from the Champagne Region in France, where a similar facility has been established, was presented at a number of community meetings to praise the benefits that the facility had brought to their region. The visit was to allay concerns of any negative impacts to agriculture and tourism if the facility goes ahead.
It was not clear how conditions in France relate to Australia. In France, privatised producers of radioactive waste have to pay to dispose of every load. Money from that ongoing stream of has been beneficial to the community surrounding the facility. Here, a one-off payment of $10 million has been committed once work on the chosen site is started. No ongoing payments have been mentioned.
DIIS and ANSTO have escorted a number of different individuals and groups, including school students, to visit Lucas Heights and demonstrate the safety of the material to be stored here. This has been reassuring to those who support the proposal.
For those with reservations it seems like a pointless and expensive exercise, knowing that nothing will be presented that is not clean, efficient and well run. ANSTO’s expertise and procedures have not been questioned.
However, it has not been publicly acknowledged by the proponents of this project that accidents can and do happen.
In 2017, a Community Benefit Package of $2 million was allocated to 11 recipients in our region to “demonstrate the Government’s commitment to the community during Phase 2”. A second $2 million package is now in the process of allocation for 2018.
An Economic Working Group (EWG) was formed to investigate and advise on economic opportunities the facility might provide. A Hawker Industry Expo is planned for May. This is despite no decision on the site’s suitability and no guarantee that the facility will actually go ahead at Barndioota.
(See attachment # 6 – Hawker Industry Expo)
A Heritage Working Group was formed to work through culturally sensitive issues and areas that might exist on the potential site, in order to progress with other on-ground surveys.
A consultant from Queensland University with expertise in community engagement has visited to speak to the BCC and HWG, with follow up visits scheduled.
A number of surveys are now under way to assess the suitability of the area to house the facility. These are the cultural or heritage survey, as well as the seismology and hydro-geology of the area.
Community expectations of jobs and other business opportunities have been raised before the site has been found to be suitable. Simultaneously, two other sites in the same electoral division are being assessed and receiving the same attention described in the dot points above. Supporters of the proposal in two communities have now been set up against each other.
DIIS states that there is no preferred site and is still accepting further nominations, including one from Leonora Shire in WA and one pending from Brewarrina in NSW.
It is publicly reported that the same cycle of strong opposition to this process has now started in Brewarrina.
- c) How any need for Indigenous support has played and will continue to play a part in the process. How will such support be determined for each stage?
Support from the Traditional Owners is vital for the project to proceed. Indigenous people were surveyed separately, outlined in the Orima Research document (pp104-105). Of 77 people surveyed only 4 lived in the specified area, the remainder living outside, but the majority of those expressed attachment to the land as owners or traditional owners. This survey showed a very high level of opposition to the proposal.
Members of the Viliwarinha Yura, traditional owners of the area proposed, and one of the core bodies making up the Adnyamathanha Traditional Landowners Association (ATLA), were speaking up very strongly against this proposal before most of the community in general were aware of it. ATLA is opposed.
- d) Whether and/or how the Community Benefit Packages affect broad community and Indigenous community sentiment.
There is more to it than just the Community Benefit Packages (CBP). It is inevitable that the introduction of money into an issue like this will affect community sentiment. This is particularly so in small communities like ours where opportunities are limited. There needs to be no distinction between the white and black communities.
A radioactive waste dump has serious implications. If it didn’t, it would not be necessary to expend so many resources over such a long period to sell the proposal to the community. From the first town meetings in Quorn and Hawker to explain the proposal, in early 2016, serious division opened in the community and remains unhealed. Those supporting the project seem uncritical and accepting. Expectations of new, unforseen opportunities have been raised and the possibilities, real or imagined, seem to outweigh all other concerns.
Those with reservations for a variety of reasons feel the community is being pushed into something without a comprehensive and public investigation of all aspects. DIIS, as the proposer, is naturally biased towards seeing the facility established, so provides information that only paints a best case scenario.
Community co-operation is the glue that holds small towns and districts together. It is essential, even more so than in the city, in times of adversity like droughts, floods and fires for communities to be cohesive. The money spent on this project – whether CBP’s, Committees or Working Groups, visiting experts, stands at local shows, trips to Lucas Heights, regular DIIS staff attendance, paying for meals on credit cards and so on – seems aimed at dispelling opposition and achieving the desired result. It has been like pouring solvent on to dissolve the glue and it remains to be seen if the split can be repaired.
- e) Whether wider (Eyre Peninsula or state-wide) community views should be taken into consideration and, if so, how is this occurring or should occur.
Radioactive waste, including the legacy material, is the Nation’s inheritance from an industry which, for its entire lifetime, has not included waste disposal as part of the process. Filling and stacking drums was never going to be a solution. This is a National issue and a National problem. Small, remote communities, whether at Kimba, the Flinders Ranges or anywhere else, should never be expected to make the decision alone to accept the toxic by-products of one industry’s lifetime production.
Considerable time and effort has been expended in trying to define “community” (Orima document, p89). This is to determine who will be eligible in each community to vote “for” or “against” accepting the facility. It is of concern that as the vote draws closer there are moves to further fine tune the roll. The only explanation could be to ensure the best chance for a “Yes” vote. Everyone knows where their community is. If you happen to be outside an arbitrary line or circle on a map, that does not exclude you from the community.
The current model to establish a NRWMF is wrong. This initiative has not come from any community. A completely new discussion needs to take place, involving all States and Territories and all other interested bodies. A uniform, national policy, formulated at COAG level, is needed. Strong leadership – bi-partisan, inclusive and empathetic – is needed.
- f) Any other related matters.
On three counts alone, the Barndioota site should never have made the short list.
- i) It is situated on the Hookina floodplain. A simple scroll over the area on Google Earth reveals the image of alluvial fans, the signature of massive historic floods and mud flows. On ground, the evidence of more recent events, the 1955 and ‘56 floods – two 100 year events in consecutive years – that washed away the narrow gauge Hookina Bridge on the iconic Ghan railway, is still obvious. Further downstream the landscape is strewn with the bleached skeletons of huge River Red Gums, 500 or more years old, ripped from the ground as living trees and carried away by the irresistible force of the water. Only a basic grasp of topography is needed to observe the “steps” in the plateaux between ranges indicating traumatic shifts of topsoil turning it into flowing mud.
(See attachments: #7, #8 & #9 – Professor CC Vonderborch documents)
- ii) The Flinders Ranges are one of the most seismically active areas in the country. The seismic record speaks for itself.
(See attachment: #10 – South Australia’s seismic footprint)
iii) Opposition from the local traditional owners, the Viliwarinha Yura and peak body, the Adnyamathanha Traditional Landowners Association. Viliwarinha Yura had been working with the owner of Wallerberdina on identifying areas of cultural significance before he nominated the site. They were not informed off the nomination, only becoming aware after Minister Frydenberg’s announcement.
Nuclear Medicine: It was impressed on the community that a primary reason for the NRWMF is the need to dispose of Australia’s radioactive medical waste. DIIS is the only official source of information, some of which implies that procedures such as CAT scans, X-Rays, and cancer treatments require the use of radioactive isotopes. Plain scans, X-Rays and a vast majority of cancer treatments do not use such isotopes.
These statements are simplistic and misleading but readily grasped and repeated by those who are uncritical, accepting and not prepared to do their homework. It is frustrating and disappointing to hear this same information being publicly stated to the Brewarrina community (attachment #12, below) two years after it was called into question in our district.
A major point has been made of the need to clear our hospitals of low level waste comprised of used gloves, gowns, syringes and other items. This was contradicted, in October 2017, by a DIIS sponsored spokesman in Hawker who “advised that nuclear waste from nuclear medicine procedures in hospitals is virtually zero……the use of nuclear medicine will not contribute to radioactive waste in hospitals……this short lived product is stored for 10 half-lives……and disposed of as hospital waste. As an example, if you receive nuclear medicine via an injection the syringe gets put in a lead lined bin and then capped, dated and sent for incineration after 10 half-lives of the longest lived radionuclide”.
(See attachment #11 – From Barndioota Consultative Committee notes, Oct 2017)
Independent information, primarily from the Medical Association for the Prevention of War (MAPW), paints a different picture and offers alternatives. This information and the authors have been publicly discredited, however their message is even more relevant now than two years ago. Medical science has made considerable advances in that time.
(See attachment #12 – MAPW open letter to the Minister) This comprehensive document offers credible alternatives for the public to weigh up against information provided by DIIS)
Jobs: “At least 15 full-time equivalent jobs”* are quoted, once the facility is established. Full-time equivalent (FTE) is a way to measure how many full-time employees would be required to perform work in a company operation. Hours paid under different working arrangements – full-time, part-time, contracted, casual – in the same workplace can be compared as an equivalent unit, based on an 8 hour day, 38 hour week. 8 people on 12 hour shifts for 6 days equate to 15 FTE’s. 15 FTE’s does not mean 15 people working in 15 full-time jobs.
Site operations are quoted as “Low-level waste: 1-2 movements per year (40 m3); Intermediate-level waste: (5 m3); Reprocessed: 2 to 3 Canisters over the life of the OPAL Reactor; Other: 1 to 2 movements per year”*. In an age where automation and remote control of daily industrial operations is becoming common it does not seem credible that 15 full time people will be required to handle a mere 5 movements of material per year in a “state-of-the art, world’s best practice” facility. A future operator may choose not to handle this potentially dangerous material with human employees.
(* Quotes from DIIS promotional brochures: “Resources, National Waste Management Project, Information Pack: Background on need for a facility, April 2016” and “National Waste Management Facility, LOOKING AHEAD, What the next stage of the NRWMF project looks like for Barndioota and surrounding communities, September, 1016”)
Expenditure: On the 11th December, 2017, Senator Patrick asked a number of questions of the Minister (Question Number: 655, 11/12/2017). There was a series of very specific requests for a breakdown of year-on-year expenditure. The reply in this regard gave a single annual figure for each year since 2015 and, presumably, an estimate for the financial year 18/19. The total of $41,676,000 is close to the size of the budget (around $42 million) that DIIS has said has been allocated to the project. The breakdown requested was not supplied.
The point is that there has been very little feed back to the community on how much is being spent and where. For example, for the Barndioota project, a second $2 million round of Community Benefit Package grants is being allocated now, but there has been minimal progress reporting on the previous allocation. It is understood that two projects from last year may not proceed. This is information that the community expects to read about in the project newsletters.
Changed Site Selection Criteria: The two sites originally nominated for the Kimba region were not proceeded with because of community opposition. Under changed guidelines, two completely different sites were nominated in 2016, this time with consent obtained from neighbours. DIIS then proceeded into Phase 2, engaging the same actions outlined for Barndioota in the section b) ii) dot points, above. Effectively, five sites in SA have been shortlisted against only three others nationally. This is heavy and undue pressure on small SA communities to carry the burden of a national problem. The Barndioota site has been progressed in spite of changed nomination criteria. This should be seen as an unfair process.
Greg Bannon, Quorn
02/04/2018
Addition to Submission – 7/05/2018:
Senate References Committee Inquiry: Since the announcement of this inquiry there has been a rapid acceleration of the process which up until now has fallen nearly 12 months behind forecast timelines. The Minister has announced the final vote to assess community support in two districts will commence on August 20th 2018. He also announced that Government’s position on co-location of Intermediate Level Radioactive Waste (ILRW) with Low Level (LLRW) at the NRWMF has changed. From being a “preferred option” it is now confirmed that the two categories will definitely be located on the same site.
On 3rd May in Kimba and 4th May in Hawker, CEO of ANSTO announced a tripling of jobs to be filled at the NRWMF, in view of the decision to co-locate the two categories of radioactive waste. A flow chart showing 45 jobs, from the original 15, was provided (see attachment #13 – New Jobs Flow Chart). This surprising and major increase in the scale of the operation has never been mentioned, signalled or intimated at any time over the last 2 ½ years spent informing the community. The Department has continually asserted that it “open and transparent”.
It has always been stated that ILRW can only be stored at the NRWNF site on a temporary basis (anything up to 100 years). For disposal, it needs to be deeply buried in a geologically stable area, in suitably stable sub-strata. No such site exists in the country and there is currently no plan to develop one. It is a genuine and valid concern that ILRW may become stranded at this facility for any number of reasons, such as climate change, national or international instability or global war, to name a few. 100 years is a long time and today’s decision makers will be long removed from any accountability.
ILRW has been the “elephant in the room” from the Day 1 of this process. The emphasis has been on Low Level Radioactive Waste and, even today, people in our community say “it is a low level waste dump”. If all these extra staff (including at least 12 for Security) are now required, when we have been told from the start that the whole facility – including temporary storage of ILRW – only required around 15 personnel, it begs the question, is there anything else that the community has not been told?
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