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Colorado’s permissive standard for plutonium in soil

In Democracy, Environment, Jefferson Parkway, Nuclear Guardianship, Plutonium, Public Health, Rocky Flats on June 23, 2013 at 2:09 am

People often express shock at recent residential and commercial developments near Rocky Flats. I’m often asked, are there no restrictions on such development in that area? For an answer to this question, one needs to look at the history of the Colorado standard for plutonium in soil in areas off the Rocky Flats site.

The dawning of public awareness about Rocky Flats 

After a major fire in one of the plutonium processing buildings at Rocky Flats on Mother’s Day 1969, NCAR radiochemist Ed Martell and Stuart Poet sampled soil east of the facility and found elevated levels of plutonium. In February 1970 when they reported their results to officials from Rocky Flats and the Colorado Health Department (CDH) they were told that what they’d found came not from the 1969 fire but either from a fire that occurred on September 11, 1957, or from leaks from thousands of drums of plutonium-laced waste stored outside in the plant’s 903 area from 1954 till 1968. These two events had not been previously revealed by either Rocky Flats or CDH. Thus began public awareness that Rocky Flats endangered public health.
 
Government scientists map plutonium contamination

In 1970 Atomic Energy Commission scientists P. W. Krey and E. P. Hardy produced this map showing plutonium contamination in soil on and off the Rocky Flats site in becquerels per square meter (one becquerel equals one disintegration or burst of radiation per second).

Microsoft Word - Krey-Hardy Clean.doc

Colorado sets a standard for plutonium in soil
In response to these revelations, in January 1973 Colorado adopted a very stringent standard of 0.2 disintegrations per minute per gram of soil (dpm/g), declaring land that exceeds this standard is unfit for residential, commercial or industrial uses.”1 Less than two months later the state increased by tenfold the amount of plutonium to which exposure was allowed, from 0.2 to 2.0 dpm/g, while at the same time it dropped its prohibition against residential, commercial, or industrial uses in areas too contaminated to meet the new, more relaxed standard. Hereafter it would merely require “special techniques” for construction in such areas, such as plowing plutonium under.2 Thus the state gutted its initial fairly protective standard for one that is essentially worthless.

Dust sampling stops a residential development near Rocky Flats
In December 1974 a Jefferson County Commissioner asked Carl Johnson, Director of the Jefferson County Health Department, whether the commissioners should permit a new residential development on land just east of the Rocky Flats site. The CDH had already approved the project, despite having found plutonium in surface soil there up to seven times the state standard (they would require plowing prior to construction). Johnson and two U.S. Geological Survey colleagues employed the innovative method of sampling only respirable dust. Dust samples taken at 25 locations showed plutonium concentrations on average 44 times greater than what had been measured at the same locations by the state using whole-soil samples. Several readings exceeded previous ones by 100 times or more, one by 285 times.3 In
September 1975, when the County Commissioners saw the results, they vetoed the residential development.

Johnson proposes that the state sample dust, not soil

In October 1975 Johnson formally proposed that for, purposes of assessing health risk, the state set a new standard based on plutonium in respirable dust on the surface of the soil. “The coarser materials which are not inhaled and retained,” he pointed out, “have no bearing on the actual hazard to health and serve only to dilute the amount of radioactivity found by analysis, and may yield a spurious low concentration of plutonium that is misleading.”4   The CDH did not welcome Johnson’s proposal.  To resolve the issue, the Colorado Land Use Commission brought in Karl Z. Morgan, former chair of the internal dose committee of both the National Council on Radiation Protection and Measurements and the International Commission on Radiological Protection and recently retired from DOE’s Oak Ridge Lab. Morgan was asked whether for assessing the public health risk from plutonium in surface soil it was better to follow Johnson in using dust samples or the CDH in collecting whole-soil samples. Morgan sided with Johnson, in favor of using samples limited to “the respirable portion, less than 5 microns dust particles.” Employing Johnson’s method, he realized, would make the State’s 2.0 dpm/g plutonium standard far more protective, since, for samples taken at the same location, Johnson’s method shows concentrations 40 or more times greater than the CDH whole-soil approach.5 Colorado officials, having gotten from Morgan the advice they sought, chose to ignore it.

Ed Martell criticizes the state standard
At an EPA hearing in Denver in 1975, Martell said that the state standard of 2.0 dpm/g equals 0.9 picocurie per gram of soil. Rounding this number off, he said that allowing 1.0 pCi/g of plutonium in surface soil “will give rise to an estimated 10 to 100 pCi/g of insoluble airborne dust of respirable size.” It thus is far from clear, he said, that the state standard “is safe and acceptable.” It may be “at least 20 times too high.”6

Conclusion

This review shows that the Colorado standard for plutonium in soil fails to protect the public in several ways:
1. The shift from an initial strict 0.2 dpm/g standard for plutonium in soil to the 2.0 dpm/g standard increased by tenfold the quantity of unregulated plutonium in off-site soil.
2. Ending the original prohibitions against residential, commercial and industrial uses gave a green light for development on contaminated land near Rocky Flats.
3. The state’s refusal to adopt the method of sampling respirable dust on the surface of soil, as recommended by Carl Johnson and Karl Morgan, means, as Martell pointed out, that people in the area are far more likely to inhale airborne particles of plutonium, the worst way to be exposed to this highly toxic material.

Notes

1.  Cleere, R.L. 24 January 1973. Public notice of plutonium contamination in the area of the Dow Chemical Rocky Flats Plant, signed R. L. Cleere, Executive Director, CDH.
2.   Amendment to the State of Colorado Rules and Regulations Pertaining to Radiation Control, Subpart RH 4.21.1, adopted Colorado State Board of Health, 21 March 1973.
3.   Johnson, C., Tidball, R. R., and Severson, R. C., “Plutonium hazard in respirable dust on the surface soil.,” SCIENCE (6 August 1976), 193:488-490.
4.  Johnson, C., to Colorado Board of Health, “Proposal of a new interim standard to define the potential airborne-plutonium particle hazard in terms of concentration of plutonium in respirable dust on the surface of the land,” 14 October 1975.
5.   Morgan, K. Z., 21 January 1976, Transcript of Presentation, Colorado Land Use Commission Meeting, pp. 12-13.
6.  Martell, E. A. January 1975. Basic considerations in the assessment of the cancer risks and standards for internal alpha emitters. Statement presented at the public hearings on plutonium standards, US EPA, Denver, pp. 17, 20.

NO to Nuclear Power

In Democracy, Environment, Plutonium, Public Health on June 8, 2013 at 2:38 am

1) NOT GREEN

  • Nuclear power can’t take us to the necessary zero-carbon economy because even reactors emit some carbon dioxide, far less than coal or gas generation but decidedly more than zero.
  • Mining, milling and enriching uranium to produce reactor fuel generate huge amounts of greenhouse gases.
  • Also, reactors release large plumes of heat directly into air and water. Reactors in both France and the US have recently had to be shut down because they overheated adjacent rivers.
  • While certain well-known environmentalists have endorsed nuclear power, no significant environmental group has done so.

2) HIGH COST AND LONG LEAD-TIME

  • To replace coal power in the U.S. and stay at roughly equal electricity levels would entail building at least 200 reactors, at the rate of one every few months over the next 30 years.
  • Costs are escalating. While $6 billion per reactor is the number often cited, utilities now estimate that one 1500 MW reactor will cost from $6 to $12 billion to build.[1]
  • Decommissioning and managing spent fuel typically costs twice what was spent on construction.
  • The NRC has not certified any new reactor design of several proposed and won’t do so soon; cost and timeline therefore are up for grabs.[2]
  • A new reactor under construction in Finland, touted for its design, was 2 years behind schedule in 2008 and 50% ($2.5 B) over the fixed cost contract.[3] Who will pick up the tab?
  • It can take 10+ years to build a facility that may operate 30 to 40 years. Building 200 reactors in 30 years would cost $1.2 to $2.4 trillion for construction and $2.4 to $4.8 trillion for cleanup. And by the time it’s completed, we’d have to start a new round.
  • “Nuclear power, once claimed to be too cheap to meter, is now too costly to matter.” (The Economist, May 19, 2001)

3) A NUCLEAR RENAISSANCE? NUMBERS SAY NO

  • Despite industry projections, the number of reactors globally peaked at 444 in 2002 and dropped to 439 in 2008, while the nuclear share of electricity generation globally dropped by a full percentage point in 2007.[4]
  • The largest nuclear power station anywhere, a 7-reactor site in Japan, was shut down in 2007 by an earthquake that registered 2 points higher on the Richter scale than the reactors’ design basis.
  • In 2008 IAEA listed 35 reactors under construction globally; 11 have been in this category for 11 years. Watts Bar, the only U.S. reactor listed had been under construction since 1977.
  • In the half century of nuclear power’s existence in the US, of 253 plants ordered 132 (52%) were built; due to cost or reliability problems 21% of these were permanently shut down, while another 27% had one or more forced outages for at least a year.[5]
  • Industry says a reactor should operate 60 years, but few make it to 40. The average age to shutdown is 22 years. Worldwide, 117 reactors have been shut down. It’s unlikely enough reactors could be built to meet the timeline for dealing with global warming.
  • Southern California Edison just announced that two of its three San Onofre reactors will be decommissioned.

4) CRITICAL SHORTAGE OF TECHNICAL PERSONNEL

  • The Organization for Economic Cooperation and Development’s Nuclear Energy Agency reported in 2004 that Finland, Germany, S. Korea, UK, and the USA require more nuclear competent engineers and scientists than are graduating.
  • Germany, which is phasing out its nuclear power program, faces a lack of enough competent personnel simply to maintain operations through closure and cleanup.
  • France needs 1500 new trained personnel per year but produces only 200.
  • US Labor Dept says a third of US nuclear industry workers are eligible to retire in the next 5 years. The industry will need to attract about 26,000 new employees over the next 10 years solely for existing facilities. The number of nuclear engineering programs at universities has declined from 65 to about 29, and these programs find attracting talented students difficult.
  • Mycle Schneider of WISE wants Greens (who are anti-nuclear) to go into this industry to help keep it safe.

5) WASTE PROBLEM

  • Reactor waste remains harmful for tens of thousands of years.
  • To build a new generation of reactors without knowing what to do with the huge quantity of radioactive waste generated by existing plants is highly irresponsible.
  • The US government has spent huge sums on an unsuccessful effort to solve this problem.
  • Yucca Mountain, touted as the solution for spent fuel, was a political, not a scientific, choice.
  • John Rowe, CEO of Exelon, the largest operator of reactors in the U.S., says nuclear power will have no future “major role” without “some federal solution to the waste problem.”[6]
  • Putting highly radioactive material in the environment, as proposed for Yucca Mountain, courts disaster.
  • The best solution to the waste problem is to stop producing it.

6) UNSAFE

  • Industry leaders like to say that new reactors are absolutely safe.
  • But all reactors routinely release some radiation to the external environment. The National Academy of Sciences affirmed in 2006 that any exposure to ionizing radiation is potentially harmful.
  • When accidents happen, they may be catastrophic.
  • The worst accidents yet, Chernobyl in 1986 and Fukushima in 2011, are downplayed by the industry. They estimate total deaths from the Chernobyl accident at about 4,000. Elizabeth Cardis of the International Agency for Cancer Research in Lyons, France, puts the number at 30,000 to 60,000. But a study done by Russian and Ukranian scientists estimates the global death toll from Chernobyl by the end of 2004 at 985,000.[7] The Fukushima accident continues to unfold, with latest reports in June 2013 citing problems with ever increasing quantities of radioactive water.
  • In 2002 the Davis-Besse plant in Ohio narrowly escaped a serious accident when inspectors found a football-size corrosion hole in the 6-inch thick steel cap. The plant had to shut down for repairs for 2 years at a cost of $600 million.
  • Charles Perrow’s Normal Accidents (1999) shows that we should expect accidents in high-risk technologies.[8]

7) TERRORIST TARGETS

  • An attack on a nuclear reactor or its cooling pond containing highly radioactive spent fuel rods could disperse radioactive debris over a large area.
  • The NRC said a fire in Vermont Yankee’s spent fuel pool could cause “25,000 fatalities over a distance of 500 miles if evacuation was 95% effective.”[9]
  • A British specialist calls nuclear power plants “pre-deployed radiological weapons” within countries terrorists may want to hit.
  • A terrorist attack on the Indian Point nuclear power plant 24 miles north of NYC could require the evacuation of as many as 10 million residents and result in untold instant and later deaths.

8) NUCLEAR PROLIFERATION

  • The technology for nuclear power can also be used to make weapons.
  • Israel, India, Pakistan, South Africa, North Korea and Iraq took this route to the bomb. Iran and others could follow.
  • Most of the world’s supply of fissile plutonium was produced as a byproduct of the operation of civilian nuclear reactors.
  • We’ll never rid the world of nuclear weapons if we don’t rid it of nuclear power.
  • Ending availability of nuclear fuel and technology would make starting a bomb program more difficult and more conspicuous and thus easier to detect and to penalize.

9) THE ALTERNATIVES

  • Large central plants – coal, gas, nuclear – are becoming more costly as more are built.
  • The alternatives to nuclear are what Amory Lovins calls “negawatts” and “micropower.”
  • Negawatts refers to electricity saved by energy efficiency or curtailment.[10]
  • Micropower comprises two types of less-centralized technologies:

a)   Generation or cogeneration of electricity onsite (not at a remote utility plant), such as gas-fired plus passive solar.

b)   Renewables (excluding big hydro) are tending to drop in cost, also to experience technological breakthroughs. The key is to mix renewables according to local and regional conditions, both to store energy and to get constant electricity generation.

  • Data compiled annually by the Rocky Mountain Institute shows that “micropower surpassed nuclear power in 2006 in total electricity production (each provides 1/6 of the world’s power), surpassed nuclear generating capacity in 2002, and is growing enormously faster.[11]
  • A recent German study confirmed that “integrated wind, PV, and biogas could reliably provide all German electricity.”[12]
  • “US windpower potential on available land is more than twice the entire US annual use of electricity.”[13]
  • Subsidies for renewables have vacillated wildly and been tiny by comparison to nuclear. The most plausible explanation for their comparative success versus nuclear and other central stations is “that they have lower costs and financial risks.”[14]
  • New nuclear is “so costly and slow . . . that it will retard the provision of energy services.”[15]
  •  In Carbon -Free and Nuclear-Free: A Roadmap for U.S. Energy Policy (Takoma Park, MD: IEER Press, 2007), Arjun Makhijani of the Institute for Energy and Environmental Research shows how the US (and other countries) can achieve the goal of zero carbon emissions within the next 30 to 50 years without reliance on nuclear power. The effort entails a mix of weaning ourselves from carbon and nuclear, applying energy efficiency across the board, and determining the blend of renewables appropriate for the region where we live. Following IEER’s rigorous but possible carbon-free and nuclear-free path would eliminate most pollution and thus improve public health.[16]

10) A POOR INVESTMENT

  • Wall Street shuns nuclear power as too expensive and too risky.
  • The industry has survived only because it’s been highly subsidized. In 2008 the industry sought $50 B in loan guarantees but got only $20 B. The target for next year is loan guarantees and other subsidies that could cost up to $200 B; the industry did not get what it sought.
  • The Congressional Budget Office says the risk of default on these loan guarantees is “very high – well above 50 percent.”
  • On March 10, 2008, Gregory Jaczko of the NRC said the federal government must put up $500 B in loan guarantees if there’s to a nuclear renaissance.[17] This has not happened.
  • In September 2008, Rep. Peter Visclosky, chair of a key committee, said programs to subsidize nuclear power are “temporary.”
  • If the industry defaults, the taxpayers will pick up the tab.
  • Forbes magazine (Feb 11. 1985) called the US experience with nuclear construction in the 1970s and 80s “the largest managerial disaster in U.S. business history, involving $100 billion in wasted investments and cost overruns.”
  • No plant ordered after 1973 was completed and all but one order placed since 1978 were canceled. The exception is two reactors under construction at the Vogtle site in Georgia.
  • There are no current orders, only placeholders in the queue for subsidies.
  • “The US nuclear revival continues to lack a key element: buyers.”[18]
  • “Every dollar invested in nuclear expansion will worsen climate change by buying less solution per dollar.”[19]

11) NON-DEMOCRATIC

  • The nuclear industry requires a centralized command structure and an information system not readily accessible to the affected public.
  • The NRC’s new process to expedite licensing of new reactors is not friendly to local populations that question industry plans.
  • John Rowe of Exelon says “you don’t start building reactors unless you have a whole lot of political support.” Moreover, increasing support in general “doesn’t necessarily mean that enough people near to a new nuclear site are supportive.”[20]
  • “The European public is still strongly opposed to the use of nuclear power; those who are worried about climate change are even more fiercely opposed.”[21]

RESOURCES

Bulletin of the Atomic Scientists (Sept/Oct 2008), issue devoted to “The future of nuclear energy”

Helen Caldicott, Nuclear Power Is Not the Answer (NY: New Press, 2006)

Richard Heinberg, The Party’s Over: Oil, War and the Fate of Industrial Societies (Gabriola Island, BC: New Society Publishers, 2003)

Amory B. Lovins and Imran Sheikh, The Nuclear Illusion (27 May 2008), p. 24. Available under Nuclear Energy on the web site of the Rocky Mountain Institute (www.rml.org)

Amory B. Lovins interviewed by Amy Goodman, July 16, 2008 http://www.democracynow.org/2008/7/16/amory_lovins_expanding_nuclear_power_makes

Arjun Makhijani, Carbon-Free and Nuclear-Free: A Roadmap for U.S. Energy Policy (Takoma Park, MD: IEER Press, 2007) For an abreviated version, go to http://www.ieer.org/sdafiles/index.html then scroll down and open Volume 15, Number 1.

Christian Parenti, “What Nuclear Renaissance?” The Nation, May 12, 2008

Mycle Schneider, Status and Trends of the World Nuclear Industry, presentation for the Alliance for Nuclear Accountability, Oak Ridge, TN, Sept. 13, 2008

Mycle Schneider, 2008 World Nuclear Industry Status Report (in three parts) http://www.thebulletin.org/web-edition/reports/2008-world-nuclear-industry-

Brice Smith, Insurmountable Risks: The Danger of Using Nuclear Power to Combat Global Climate change (Takoma Park, MD: IEER Press, 2006)

WISE (World Information Service on Energy)

Effects of resuming uranium mining in the western states of the USA: http://www.tomdispatch.com/post/174946/Tomgram%3A%20%20Chip%20Ward%2C%20Uranium%20Frenzy%20in%20the%20West


[1] FPL estimate in Feb 08 is $5,000 to $7,000/kW, or $13-$14 B for two unit plant; five months later FPL filed formal estimate of $12 to $24 billion for the two reactors. (Lovins 6) Lovins details reasons for cost increases, esp. for the US where qualified suppliers have declined from about 400 in the 1980s to 80 today.

[2] Harvey Wasserman, “New nukes not ready for prime time: Nuclear Regulatory Commission deals devastating blow to nuclear power industry,” CounterPunch, July 25, 2008

[3] Olkiliuoto-3, Finland (Areva): Environmental Impact Assessment 1998-99; application approved 2002; site selected 2003; construction began 2005. By 2007, running 24 months late; expected startup 2011. Lead time, 12-13 years since EIA. Guaranteed fixed price €3 B ($4.33 B); cost overrun 2 years after construction start, €1.5 B ($2.66 B).

[4] Mycle Schneider, Alliance for Nuclear Accountability presentation, 9-11-08.

[5] Amory B. Lovins and Imran Sheikh, The Nuclear Illusion (27 May 2008), p. 24. Available under Nuclear Energy on the web site of the Rocky Mountain Institute (www.rml.org)

[6] Bulletin of the Atomic Scientists, Sept/Oct 2008, p. 12.

[7] Alexey V. Yablolov, Vassily B. Nesterenko and Alexey V. Nesterenko, Chernobyl: Consequences of the Catastrophe for People and the Environment, Annals of the New York Academy of Sciences, vol. 1181 (2009), p. 210.

[8] Notes based on chap. 3 of Helen Caldicott, Nuclear Power Is Not the Answer (2006).

  • Fissioning uranium in reactors creates more than 200 human-made nuclear elements.
  • In the USA we are routinely exposed to c. 100 mrem of naturally occurring radiation. If 125 people receive this dose annually for 70 years, one will get cancer.
  • Yet NRC allows an additional 100 mrem/y exposure from nuclear reactors.
  • Standards are set to protect the “standard man” not the most vulnerable – very young, very old, infirm.
  • There are some 80,000 chemicals in common use; little is known about the synergistic effects of mixing non-radioactive toxins with radiation.
  • NAS says man-made radiation accounts for 18% of human exposure. Caldicott thinks this percentage will increase with more leaks from radioactive materials in the environment.

[9] Christian Parenti, “What Nuclear Renaissance?” The Nation, May 12, 2008, p. 16.

[10] Every dollar invested in energy efficiency removes seven times more CO2 from the atmosphere than a dollar invested in nuclear power. But according to Richard Heinberg, The Party’s Over: Oil, War and the Fate of Industrial Societies (2003), “the curtailment of energy usage offers clearer benefits than improved efficiency. . . . (E)ventually curtailment means reducing economic activity. . . It means fundamental changes not only in the pattern of life but also in the quality of life that we have become accustomed to.” (p. 163)

[11] Lovins and Sheikh, p. 29. “Dismissed as unimportant, uneconomic, unreliable, and futuristic, micropower in 2005 provided from one-sixth to more than half of all electricity in a dozen industrial countries, including 53% in Denmark, 38% in Finland and Holland, 31% in Russia, 20% in Germany, 17% in Japan and Poland, vs. 6% in the United States, which still has many barriers to fair competition.” (p. 31)

[12] Lovins and Sheikh, p. 23

[13] Lovins and Sheikh, p. 23

[13] Lovins and Sheikh, p. 40

[14] Lovins and Sheikh, p. 35

[15] Lovins and Sheikh, p. 37

[16] See http://www.ieer.org/sdafiles/index.html and go to vol. 15, no 1

[17] Selena Williams, “US Government Loan Guarantees for New Nuclear Too Small — NRC,” Dow Jones Newswires, March 10, 2008

[18] Lovins and Sheikh, p. 49. In Jan 07 Standard and Poor’s said it “does not anticipate construction of new [US] plants to start in the next few years. . .  The challenges. . .can be extremely risky,” with operating risk “inherently” higher than average. (Lovins 46)  “Market behavior increasingly suggests that the ever more heroic nuclear subsidies wil elicit the same response as defibrillating a corpse: it will jump, but it won’t revive.” (Lovins, 49)   Under the Price-Anderson Act (initially passed in 1957), the federal govt. is responsible for major liability costs (over $10 B).

[19] Lovins and Sheikh, p. 15

[20] Bulletin of the Atomic Scientists, Sept/Oct 08, pp. 10, 13

[21] Gallup, April 2007; quoted in Mycle Schneider, ANA 13 Sept. 08

Nuclear Workers faced hidden dangers that became health problems for their families

In Environment, Nuclear Guardianship, Public Health, Workplace exposure on June 6, 2013 at 2:00 am

See the full article at   http://www.huntingtonnews.net/64104

Very bad news: EPA posts new Protective Action Guides for nuclear events

In Democracy, Environment, Public Health on June 5, 2013 at 2:12 am

The EPA should be called the Enterprise Protection Agency for issuing new Protection Action Guides (PAGs) that greatly relax existing standards for protecting the public and the environment in the USA in the event of a major accident at a nuclear power plant (think Fukushima, Chernobyl, Three Mile Island), attack with a “dirty” (radioactive) bomb, releases from nuclear fuel or weapons facilities, or major transportation accident. EPA is implementing these new PAGs even though it is still collecting public comments on them. For more detail on this see http://readersupportednews.org/news-section2/312-16/17724-epa-dramatically-weakens-radiation-protection

Communications Coordinator employed

In Environment, Jefferson Parkway, Nuclear Guardianship, Plutonium, Public Health, Rocky Flats on June 5, 2013 at 1:51 am

A couple of weeks ago I posted a notice on this blog as well as in other locations that we at the Rocky Mountain Peace & Justice Center were seeking a part-time Communications Coordinator for our Rocky Flats Nuclear Guardianship project. We especially wanted a person who could help us with social media, writing and outreach. Among those who applied was Cecelia Gilboy, who seemed just what the doctor ordered. We felt honored that she applied for the position and hired her. You will soon be seeing the fruit of her work.

Kristen Iversen’s FULL BODY BURDEN is now available in paperback

In Environment, Nuclear Guardianship, Plutonium, Public Health, Rocky Flats, Wildlife Refuge on June 5, 2013 at 1:39 am

Kristen’s book,  in my opinion, is the best single work for people unfamiliar with Rocky Flats to read. She is a masterful story teller, and her work is closely documented.

For details, see http://us5.campaign-archive1.com/?u=b091790d7900d4ee97eaee42b&id=c4d32ebed0&e=8d91909c83

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