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HomeMy WebLinkAbout02. Water Public Health Goals AGENDA MEMO DATE: July 27, 2010 TO: Mayor and Members of the City Council FROM: Office of the City Manager By: John Oskoui, P.E., Director of Public Works SUBJECT: CITY OF DOWNEY WATER SYSTEM 2010 REPORT ON PUBLIC HEALTH GOALS RECOMMENDATION That the City Council: 1. Conduct a Public Hearing to consider comments on the City’s water system 2010 Report on Public Health Goals; and ADOPT A RESOLUTION OF THE CITY COUNCIL OF THE CITY OFDOWNEY 2. ADOPTING THE CITY OF DOWNEY WATER SYSTEM 2010 REPORT ON PUBLIC HEALTH GOALS BACKGROUND Provisions of the California Health and Safety Code (Section 116470) specify that a public water system serving more than 10,000 service connections must prepare a Public Health Goals Report (Report) by July 1, 2010 that provides information on the “detection” of any contaminants in the public water system from 2007 through 2009 that exceed Public Health Goals (PHGs). The attached Report must be advertised and made available for public review, and be presented to the public for comment at a public hearing. The purpose of the Report is to provide water customers with access to information on levels of contaminants that fall below the enforceable mandatory standards, such as Maximum Contaminant Levels (MCLs) that are established by the United States Environmental Protection Agency (USEPA) and the California Department of Public Health (CDPH). MCLs are the regulatory definition of what is safe for human consumption. Adopted MCLs are the criteria utilized to ensure that a public water system is in compliance with drinking water standards. PHGs are non-enforceable goals established by the California Environmental Protection Agency (Cal-EPA)’s Office of Environmental Health Hazard Assessment (OEHHA) and are not required to be met by any public water system. The law also requires that where OEHHA has not adopted a PHG for a constituent, the water suppliers are to use the Maximum Contaminant Level Goals (MCLGs) adopted by the USEPA. The report must also include design, construction and operational cost estimates for treatment facilities that can reduce or eliminate any trace of the contaminant(s) from drinking water sources and/or supplies without regard to how minimal the risk might be. CITY OF DOWNEY, CALIFORNIA Mayor and Members of the City Council City of Downey Water System Report On Public Health Goals July 27, 2010 Page 2 DISCUSSION Drinking Water Standards, PHGs and MCLGs PHGs are set by the OEHHA and are based solely on public health risk considerations. None of the practical risk-management factors that are considered by the USEPA or the CDPH in setting drinking water standards (MCLs) are considered in setting the MCLGs or PHGs. These factors include analytical detection capability, treatment technology availability, benefits and costs. PHGs and MCLGs are, or may be set at, very low levels where the health risks are very low or, in the case of MCLGs of zero, the health risk is zero. Determinations of health risk at these low levels are based on theoretical risk assessments utilizing many assumptions and mathematical extrapolations. Many contaminants are considered to be carcinogenic and the USEPA has set the MCLGs for these contaminants at zero. Included in the Report is the numerical public health risk associated with the MCL, PHG or MCLG, the category or type of risk to health that could be associated with each constituent, the best treatment technology available that could be used to reduce the constituent level, and an estimate of the annualized cost of the treatment system. Water Quality Data Considered All of the water quality data resulting from the analysis of the water quality samples collected from the City’s water system between 2007 and 2009 for purposes of determining compliance with drinking water standards was considered. This data was summarized in the 2007, 2008, and 2009 Annual Water Quality Reports (Consumer Confidence Report or CCR), which were mailed to all of our customers before July 1 of the following year. Treatment Alternatives and Cost Estimates Both the USEPA and CDPH adopt what are known as Best Available Technologies (BATs), which are the best known methods of reducing contaminant levels to the MCL. Costs can be estimated for such technologies. However, since many PHGs and MCLGs are set much lower than the MCL, it is neither always possible nor feasible to determine what treatment is needed to further reduce a constituent downward to, or near, the PHG or MCLG, many of which are set at zero. Estimating the costs to reduce a constituent to a low PHG level (sometimes to non-detect levels or zero) is difficult, if not impossible, and highly speculative because it is not possible to verify by analytical means that the level has been lowered to zero. In some cases, installing a treatment facility to further reduce very low levels of one constituent may have adverse effects on other aspects of water quality. Therefore, they have limited value and may not warrant significant investment of time and money. Where appropriate, the BAT that could be used to reduce the constituent level, and an estimate of the annualized cost to design, construct and operate the treatment facility have been estimated. This annualized cost assumes that the cost will be equally shared by each of the 22,500 service connections in the City’s potable water system. Mayor and Members of the City Council City of Downey Water System Report On Public Health Goals July 27, 2010 Page 3 Constituents Detected That Exceed a PHG or a MCLG The following are constituents that were detected in one or more of the City’s drinking water sources at levels above the PHG, or if no PHG exists, above the MCLG. Constituents MCL PHG or (MCLG) Detection Tetrachloroethylene [PCE] (mg/L) 0.005 0.00006 0.0006 Arsenic (mg/L) 0.010 0.000004 0.0012 Gross-Alpha (pCi/L) 15 (0) 1.4 Uranium (pCi/L) 20 0.43 2.6 Lead (mg/L) – Action Level 0.015 0.0002 0.007 Copper (mg/L) – Action Level 1.3 0.3 0.35 Coliform (% Positive Samples) 5% (0) ND-7.8% The detailed discussion and cost estimates for their treatment are presented in the attached 2010 Report on Public Health Goals. FINANCIAL IMPACT The drinking water quality of the City of Downey potable water system meets all CDPH and USEPA drinking water standards set to protect public health. Additional costly treatment processes would be required to further reduce the levels of the constituents identified in the 2010 Report on Public Health Goals, which are already significantly below the MCLs established to provide “safe drinking water”. The costs associated with the Best Available Treatment Technology are rough estimates for capital equipment installation and operational expenditures. Other associated costs, such as land acquisition to meet facility space requirement, are not included. The effectiveness of the treatment processes to provide significant reductions in constituent levels at these already low levels is uncertain. The health protection benefits of these further hypothetical reductions are not at all clear and may not be quantifiable. Therefore, no action is proposed. Attachments: Resolution 2010 Report on Public Health Goals S:\AgendaMemosCC2010\07-27-10\PHG Adoption RESOLUTION NO. 10-_____ A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DOWNEY ADOPTING THE 2010 CITY OF DOWNEY WATER SYSTEM REPORT ON PUBLIC HEALTH GOALS WHEREAS, Provisions of the California Health and Safety Code (Section 116470) specify that a public water system serving more than 10,000 service connections must prepare a Public Health Goals Report (Report) by July 1, 2010 that provides information on the detection of any contaminants in the public water system from 2007 through 2009 that exceed the Public Health Goals (PHGs). WHEREAS, the City is an urban supplier of water providing water to a population of approximately 112,000 through approximately 22,500 service connections; and WHEREAS, the City provides over 17,000 acre-feet of water to its customers annually; and WHEREAS, Section 116470 requires that the Report be prepared every three years; and WHEREAS, Section 116470 requires that the Report be made available for public inspection and that a public hearing be held prior to adoption of the Report; and WHEREAS, the City has, therefore, prepared and made available for public review, copies of the Report, and provided proper notice of the public hearing to be held before the City Council of the City of Downey on July 27, 2010; and WHEREAS, all remarks and suggestions brought to the attention of the City were considered prior to the adoption of the Report. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF DOWNEY DOES HEREBY RESOLVE AS FOLLOWS: SECTION 1 . The City of Downey Water System 2010 Report On Public Health Goals is hereby adopted and ordered filed with the City Clerk; SECTION 2 . The Public Works Director is hereby authorized and directed to make available to the public copies of the Report no later than 30 days after Council adoption; SECTION 3. The City Clerk shall certify to the adoption of this Resolution. RESOLUTION NO. 10-_____ PAGE 2 APPROVED AND ADOPTED this 27th day of July, 2010. ANNE M. BAYER, Mayor ATTEST: KATHLEEN L. MIDSTOKKE, City Clerk I HEREBY CERTIFY that the foregoing Resolution was adopted by the City th Council of the City of Downey at a regular meeting held on the 27 day of July, 2010, by the following vote, to wit: AYES: Council Members: NOES: Council Member: ABSENT: Council Member: ABSTAIN: Council Member: KATHLEEN L. MIDSTOKKE, City Clerk . . . Utilities Division . . Department of Public Works . . .9252 Stewart & Gary Road . . Downey, CA 90241 City of Downey Water System 2010 Report on Public Health Goals .......... Prepared by Utilities Division Department of Public Works City of Downey June 2010 2010 Report on Public Health Goals Background Provisions of the California Health and Safety Code (Section 116470) specify that a public water system serving more than 10,000 service connections must prepare a special report (Report) by July 1, 2010 that gives information on the “detection” of any contaminants that exceeded any Public Health Goals (PHGs). PHGs are non- enforceable goals established by the California Environmental Protection Agency (Cal-EPA)’s Office of Environmental Health Hazard Assessment (OEHHA). The law also requires that where OEHHA has not adopted a PHG for a constituent, the water suppliers are to use the Maximum Contaminant Level Goals (MCLGs) adopted by the United States Environmental Protection Agency (USEPA). MCLGs are the federal equivalent to PHGs. The purpose of this report is to provide water customers access to information concerning those contaminants in the City’s potable water system whose levels exceed any PHG or MCLG. Additionally, the Report provides cost estimates to construct and operate a treatment facility that would reduce or eliminate any trace of the contaminant(s) from drinking water to meet PHGs or MCLGs without regard to how minimal the risk might be. Drinking Water Standard, MCLs, PHGs and MCLGs The USEPA and California Department of Public Health (CDPH or DPH) establish drinking water standards at very conservative levels to protect consumers against all but very low to negligible health risks. MCLs are the regulatory definition of what is “safe”. Adopted MCLs are the criteria utilized to ensure that a public water system is in compliance with drinking water standards. Per standard health effects language specified in California Drinking Water Regulations, Title 22, Code of Regulations, drinking water which meets DPH standards is associated with little to no risk and should be considered safe. PHGs set by the OEHHA are based solely on public health risk considerations. None of the practical risk-management factors, which are considered by the USEPA or the CDPH in setting drinking water standards (MCLs), are considered in setting the MCLGs or PHGs. These factors include analytical detection capability, treatment Attachment No. 1 technology available, benefits and costs. is a list of all regulated contaminants with their MCLs and PHGs or MCLGs. PHGs and MCLGs are set at very low levels where the health risks are very low or, in the case of zero, the health risk is zero. Determinations of health risk at these low 2 levels are frequently based on theoretical risk assessments with many assumptions and mathematical extrapolations. Many contaminants are considered to be carcinogenic and the USEPA has set their MCLGs at zero, which cannot be measured by the practical available analytical methods. PHGs and MCLGs are not regulatory in nature and represent only non-mandatory theoretical goals. Water Quality Data Considered All of the water quality data resulting from the analysis of the quarter quality samples collected from the City’s water system between 2007 and 2009 for purposes of determining compliance with drinking water standards was considered. This data was summarized in the 2007, 2008, and 2009 Annual Water Quality Reports (Attachments 2, 3 and 4 respectively), or referred to as a Consumer Confidence Report (CCR), which were mailed to all of our customers before July 1 of each year. If a constituent was detected in the water supply at a level above an applicable PHG or MCLG, this Report provides the information required by the law. Included is the numerical public health risk associated with the MCL and the PHG or the MCLG, the category or type of risk to health that could be associated with each constituent level, and an estimate of the annualized cost of the treatment system if it is appropriate and feasible. Best Available Treatment Technology and Cost Estimates Both the USEPA and CDHS adopt what are known as BATs or Best Available Technologies which are the best known methods of reducing contaminant levels to the MCL. However, since many PHGs and MCLGs are set much lower than the MCLs, it is neither always possible, nor feasible, to determine what treatment is needed to further reduce a constituent downward to, or near, the PHG or MCLG, many of which are set at zero. Estimating the costs to reduce a constituent to a low PHG level (sometimes to non- detect levels, or zero) is difficult, if not impossible and highly speculative because it is not possible to verify by analytical means. In some cases, installing a treatment facility to further reduce levels of one constituent that already is at a very low level may have adverse effects on other aspects of water quality. Where feasible and the BAT that could be used to reduce the constituent level exists, the annualized cost to design, install and operate that treatment has been estimated. The cost estimates for each service connection are calculated by assuming that the cost will be equally shared by each of the 22,500 service connections in the water system. 3 Constituents Detected That Exceed a PHG or a MCLG The following are discussions of those constituents that were detected in one or more of the City’s drinking water sources at levels above the PHG, or the MCLG. The table below is a brief summary of those constituents. Constituents MCL PHG or Detection BATs (MCLG) Tetrachloroethylene [PCE] (mg/L) 0.005 0.00006 0.0006 GAC Arsenic (mg/L) 0.010 0.000004 0.0012 RO Gross-Alpha (pCi/L) 15 (0) 1.4 RO Uranium (pCi/L) 20 0.43 2.6 RO Lead (mg/L) – Action Level 0.015 0.0002 0.007 Corrosion Control Copper (mg/L) – Action Level 1.3 0.3 0.35 Corrosion Control Coliform (% Positive Samples) 5% (0) ND-7.8% Disinfection Tetrachloroethylene (PCE) There are a total of five wells that have PCE levels below the MCL but above the PHG. The category of health risk associated with PCE, and why it has a drinking water standard, is that ingesting water containing PCE above the MCLs throughout a lifetime may increase the risk of developing cancer. Per Drinking Water Regulation of Section 64468.2, Title 22, CCR,that “Drinking water which meets this standard (the MCLs) is associated with little to none of this risk and should be considered safe with respect to PCE.” A feasible BAT for removal of PCE is Granular Activated Carbon (GAC). Since the PCE level in the subject wells is already below the MCL, the GAC unit would require long empty bed contact time (EBCT). The estimated annualized capital and operational cost for such a treatment systems for five wells would be approximately $5.5 million per year including annualized capital and operation and maintenance costs. This would result in an estimated increased cost for each water service customer of $244 per year. Arsenic Arsenic has been detected from 12 water wells in the system. The MCL is 0.010 mg/L and the PHG is 0.000004 mg/L (4 ppt). The levels detected in the City’s system were below the MCL but above the PHG level. Arsenic is a naturally occurring element in the earth's crust and is widely distributed in the environment. All humans are exposed to microgram quantities of arsenic largely from food and to a lesser degree from drinking water and air. The PHG of 4 0.000004 mg/L for arsenic in drinking water is derived based on the mortality of arsenic-induced lung and urinary bladder cancers observed in epidemiological studies of populations in Taiwan, Chile, and Argentina. Similar unit risks were derived from a mouse bioassay using prenatal exposure to arsenic. The risk estimates were based on a low-dose linear extrapolation approach although the mode of carcinogenic action is not fully understood. The applicable BAT identified to treat arsenic is Reverse Osmosis (RO) treatment. The City has determined that the cost to install and operate a RO removal system to treat the subject wells in the water system to meet PHG levels would be approximately $40 million annually, which includes construction and annual operational cost. This translates into an annual cost of $1,764 per water service connection. Gross Alpha and Uranium Gross Alpha has been detected from all 20 wells in the system. The MCL is 15 picoCuries per Liter (pCi/L) and the MCLG is 0 pCi/L. The levels detected in our system were below the MCL, but were over the MCLG levels. Uranium has been detected from all 20 wells. The MCL is 20 pCi/L and the PHG is 0.43 pCi/L. The levels detected in our system were below the MCL, but were over the PHG level. These radiological constituents are naturally occurring contaminants in water supplies. These constituents have been shown to cause cancer in laboratory animals such as rats and mice when the animals are exposed to high levels over their lifetimes. Constituents that cause cancer in laboratory animals may also increase the risk of cancer in humans who are exposed over long periods of time. CDPH has set the drinking water standards for gross alpha at 15 pCi/L, and for uranium at 20 pCi/L to reduce the risk of cancer that has been observed in laboratory animals. The BAT identified to treat these radiological contaminants (Gross Alpha and Uranium) is Reverse Osmosis (RO) treatment. We have determined that the cost to install and operate RO systems at the City’s well sites system to meet the PHG levels would be approximately $81 million annually, which includes construction and annual operational cost. This translates into an annual cost of $3,580 per water service connection. Coliform Bacteria Coliform bacteria are an indicator organism that are ubiquitous in nature and are not generally considered harmful. They are used because of the ease in monitoring and analysis. If a positive sample is found, it indicates a potential problem that needs to 5 be investigated. It is not at all unusual for a system to have an occasional positive sample. It is difficult, if not impossible to assure that a system will never detect a positive sample. The MCL for coliform is 5% positive samples of all system samples taken on a monthly basis and the MCLG is zero. The reason for the coliform drinking water standard is to minimize the possibility of the water containing pathogens which are organisms that cause waterborne diseases. Coliform is only a surrogate indicator of the potential presence of pathogens, therefore, it is not possible to quantify its health risk. Per the CDHS Total Coliform Rule, 25 total coliform samples are collected each week from locations throughout the distribution system. During the three-year period of 2007 and 2009, there were two months where the monthly positive percentage exceeded the PHG of zero: December 2007 (1.0%), and September 2008 (7.8%). All positive samples were followed by corresponding actions including collecting confirmation samples, and investigating and correcting cause of positive samples. BATs have been implemented and will continue to be utilized to prevent any microbiological contamination. These include protection of wells by appropriate construction and maintenance, proper preventative maintenance of the distribution system such as flushing, an effective cross-connection control program, an effective monitoring and surveillance program and maintaining positive pressures in the distribution system. Lead and Copper There is no MCL for lead or copper. Instead the 90th percentile value of all samples from household taps in the distribution system cannot exceed an Action Level by the CDPH of 0.015 mg/L for lead and 1.3 mg/L for copper. The PHG for lead is 0.0002 mg/L and the PHG for copper is 0.3 mg/L. The category of health risk for lead is damage to the kidneys or nervous system, while the category of health risk for copper is gastrointestinal irritation. Based on extensive sampling of our distribution system, the 90th percentile value for lead was 0.007 mg/L and for copper was 0.35 mg/L. The City’s system is in full compliance with the Lead and Copper Rule. Therefore, the system is deemed by CDPH to have “optimized corrosion control” for our water system. In general, optimizing corrosion control is considered to be the BAT to deal with corrosion issues and any lead or copper findings. We continue to monitor our water quality parameters that relate to corrosivity, such as the pH, hardness, alkalinity, and total dissolved solids, and will take action if necessary to maintain our system in an “optimized corrosion control” condition. 6 Since we are meeting the “optimized corrosion control” requirements, it is not prudent to initiate additional corrosion control treatment as it involves the addition of other chemicals and there could be additional water quality issues raised. Therefore, no estimate of cost has been included. Recommendations For Further Action The drinking water quality of the City of Downey’s water system meets all State and Federal drinking water standards set to protect public health. Additional costly treatment processes would be required to further reduce the levels of the constituents identified in this report, which are already significantly below the MCLs established to provide “safe drinking water”. The effectiveness of the treatment processes to provide significant reductions in constituent levels at these already low values is uncertain. The health protection benefits of these further hypothetical reductions are not at all clear and may not be quantifiable. Therefore, no action is proposed. Attachments 1.Table of Regulated Contaminants with MCLs, PHGs or MCLGs 2.2007 Water Quality Report 3.2008 Water Quality Report 4.2009 Water Quality Report 7 Attachment No.1 MCLs, DLRs and PHGs for Regulated Drinking Water Contaminants Last Update: December 31, 2009 StatePHG or Date of DLR MCL(MCLG)PHG Gross beta particle activity - OEHHA concluded in 2003 that a PHG was not 4 mrem/yr4(zero)n/a practical Radium-226--10.052006 Radium-228--10.0192006 Radium-226 + Radium-228 (addressed 5------ together as one MCL) Strontium-90 820.352006 Tritium 20,0001,0004002006 Uranium 2010.432001 Chemicals with MCLs in 22 CCR §64444—Organic Chemicals (a) Volatile Organic Chemicals (VOCs) Benzene 0.0010.00050.000152001 Carbon tetrachloride 0.00050.00050.00012000 1997 1,2-Dichlorobenzene0.60.00050.6 (rev2009) 1,4-Dichlorobenzene (p-DCB) 0.0050.00050.0061997 1,1-Dichloroethane (1,1-DCA)0.0050.00050.0032003 1999 1,2-Dichloroethane (1,2-DCA)0.00050.00050.0004 (rev2005) 1,1-Dichloroethylene (1,1-DCE)0.0060.00050.011999 cis-1,2-Dichloroethylene0.0060.00050.12006 trans-1,2-Dichloroethylene0.010.00050.062006 Dichloromethane (Methylene chloride)0.0050.00050.0042000 1,2-Dichloropropane0.0050.00050.00051999 1999 1,3-Dichloropropene0.00050.00050.0002 (rev2006) Ethylbenzene0.30.00050.31997 Methyl tertiary butyl ether (MTBE) 0.0130.0030.0131999 Monochlorobenzene0.070.00050.22003 c Styrene 0.10.0005 (0.1) 1,1,2,2-Tetrachloroethane0.0010.00050.00012003 Tetrachloroethylene (PCE) 0.0050.00050.000062001 Toluene0.150.00050.151999 1,2,4-Trichlorobenzene 0.0050.00050.0051999 1,1,1-Trichloroethane (1,1,1-TCA)0.20.000512006 1,1,2-Trichloroethane (1,1,2-TCA)0.0050.00050.00032006 Trichloroethylene (TCE) 0.0050.00050.00172009 Trichlorofluoromethane (Freon 11)0.150.0050.71997 1,1,2-Trichloro-1,2,2-Trifluoroethane (Freon 1.20.0141997 113) Vinyl chloride 0.00050.00050.000052000 Xylenes 1.750.00051.81997 (b) Non-Volatile Synthetic Organic Chemicals (SOCs) Alachlor 0.0020.0010.0041997 Atrazine 0.0010.00050.000151999 MCLs, DLRs and PHGs for Regulated Drinking Water Contaminants Last Update: December 31, 2009 StatePHG or Date of DLR MCL(MCLG)PHG 1999 Bentazon 0.0180.0020.2 (rev2009) d Benzo(a)pyrene 0.00020.00011997 0.000004 Carbofuran0.0180.0050.00172000 1997 Chlordane 0.00010.00010.00003 (rev2006) 1997 Dalapon 0.20.010.79 (rev2009) 1,2-Dibromo-3-chloropropane (DBCP)0.00020.000011.7E-061999 2,4-Dichlorophenoxyacetic acid (2,4-D)0.070.010.022009 Di(2-ethylhexyl)adipate 0.40.0050.22003 Di(2-ethylhexyl)phthalate (DEHP) 0.0040.0030.0121997 Dinoseb 0.0070.0020.0141997 Diquat0.020.0040.0152000 1999 Endrin 0.0020.00010.0018 (rev2008) Endothal 0.10.0450.581997 Ethylene dibromide (EDB)0.000050.000020.000012003 Glyphosate 0.70.0250.92007 Heptachlor 0.000010.000010.0000081999 Heptachlor epoxide 0.000010.000010.0000061999 Hexachlorobenzene0.0010.00050.000032003 Hexachlorocyclopentadiene0.050.0010.051999 1999 Lindane0.00020.00020.000032 (rev2005) Methoxychlor0.030.010.031999 Molinate0.020.0020.0012008 Oxamyl0.050.020.0262009 Pentachlorophenol (PCP)0.0010.00020.00032009 Picloram 0.50.0010.51997 Polychlorinated biphenyls (PCBs)0.00050.00050.000092007 Simazine0.0040.0040.0042001 2,4,5-TP (Silvex)0.050.0010.0252003 -8-9e 2,3,7,8-TCDD (dioxin) 3x105x10(0) Thiobencarb0.070.0010.072000 Toxaphene0.0030.0010.000032003 Chemicals with MCLs in 22 CCR §64533—Disinfectant Byproducts Total Trihalomethanes0.08 f ------ Bromodichloromethane0.0005(zero) -- Bromoform0.0005(zero) -- Chloroform0.0005(0.07) -- Dibromochloromethane0.0005(0.06) -- Total Haloacetic Acids ---- 0.06-- Monochloroacetic acid0.002(0.07) Dichloroacetic acid0.001(zero) Trichloroacetic acid0.001(0.02) Bromoacetic acid0.001-- Dibromoacetic acid0.001-- Yellow highlights indicate contaminant regulations revised since 2007 Note: Yellow highlights indicate contaminant regulations revised since 2007 Attachment No.2 Attachment No.3 ôÍÅóÉïÃøÊÓÎÑÓÎÕåÛÈ×Êè×ÉÈ×Øý ã 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