Download Environmental Effects - Environmental Protection Authority

IN THE MATTER
of the Exclusive Economic Zone and Continental Shelf
(Environmental Effects) Act 2012
AND
IN THE MATTER
of a Decision-Making Committee appointed by the
Environmental Protection Authority to consider a marine
consent application by Chatham Rock Phosphate Ltd to
undertake activities in the Chatham Rise restricted by the
Exclusive Economic Zone and Continental Shelf
(Environmental Effects) Act 2012
STATEMENT OF EVIDENCE OF Louis Tremblay (Ecotoxicological impacts)
15 September 2014
Counsel: Myregel Carambas, Solicitor / Morgan Slyfield, Barrister
Email: [email protected]
Tel: 64-4-474 5439
Environmental Protection Authority
Grant Thornton House, 215 Lambton Quay
Private Bag 63002, Wellington 6140
INTRODUCTION
1.
My name is Louis Tremblay.
2.
I am a scientist and senior lecturer in environmental toxicology and am
employed by the Cawthron Institute and the University of Auckland.
3.
I have been engaged by the Environmental Protection Authority (“EPA”), at
the direction of the Decision-Making Committee, to:
(a)
prepare a report that critically appraises the application information in
terms of the assessment of effects of the activity on ecotoxicology
considering submissions, further information received, the EPA staff
report, applicant’s evidence; and
(b)
participate in expert conferencing, and the hearing of the marine
consent application, if directed to do so by the Decision-Making
Committee.
4.
I have prepared, in conjunction with Dr Olivier Champeau, a report entitled A
Critical appraisal of potential ecotoxicological effects on the environment
associated with the Chatham Rock Phosphate Ltd (CRP) marine consent
application (15 September 2014). A copy of the report is attached to this
statement of evidence as Annexure A. Dr Olivier Champeau is an
ecotoxicologist on my team who assisted me with scanning the material listed
in paragraph 8, below, for information relevant to the ecotoxicological
assessment, and peer-reviewing the report.
QUALIFICATIONS AND EXPERIENCE
5.
I have the following qualifications and experience relevant to the evidence I
have provided:
(a)
Bachelor of Science (Biology) from the University of Montreal, a Master
of Science (Microbiology) from McGill University, and a Doctorate of
Philosophy (Zoology) from the University of Guelph;
(b)
I am an environmental toxicologist employed by the Cawthron Institute
and a Senior Lecturer in ecotoxicology with the School of Biological
Sciences, University of Auckland. I have worked in the Cawthron
1
Coastal & Freshwater Group for nearly 4 years and joined the
University of Auckland over 2 years ago at 0.2 FTE. Prior to this, I
worked 12 years as an environmental toxicologist with Landcare
Research;
(c)
I have published over 50 peer-reviewed scientific papers in
environmental toxicology and hazard characterisation. I have produced
over 175 conference presentations and scientific reports in the field of
endocrine disruption and environmental toxicology;
(d)
I am on the council of the Society of Environmental Toxicology and
Chemistry (SETAC) Australasia. I am on the editorial board of the
international journals Biomarkers and Ecotoxicology and Environmental
Safety.
CODE OF CONDUCT
6.
I confirm that I have read, and agree to comply with, the Code of Conduct for
Expert Witnesses as contained in the Environment Court Consolidated
Practice Note 2011.
7.
In particular, unless I state otherwise below, this evidence is within my
sphere of expertise and I have not omitted to consider material facts known
to me that might alter or detract from the opinions I express.
SCOPE OF EVIDENCE
8.
When authoring the report described at paragraph [4] above, I relied upon
sections relevant to metals in:
(a)
Sections 5, 6, 8, and 10 of the Chatham Rock Phosphate Limited –
Proposed Mining Operation, Chatham Rise Marine Consent Application
and Environmental Impact Assessment report; the CRP Request for
Further Information – Request Nos. 8 to 11, 16 & 19 report; Appendix
11 Review of Sediment Chemistry and Effects of Mining (Golder
2014a); Appendix 12 Natural Sedimentation on the Chatham Rise
(Nodder 2013); Appendix 13 Data on the Chatham Rise benthos:
Macro-faunal and in-faunal communities (Beaumont et al. 2013a);
Appendix 15 Benthic communities on MPL area 50270 on the Chatham
2
Rise (Rowden et al. 2013); Appendix 16 Benthic epifauna communities
of the central Chatham Rise crest (Rowden et al. 2014a); Appendix 29
Impacts of sedimentation arising from mining on the Chatham Rise
(Hewitt & Lohrer 2013); CRP Marine consent application and
environment impact assessment Response to Request for Further
Information (Part1); CRP Marine consent application and environment
impact assessment Response to Request for Further InformationRequest No. 6; CRP Marine consent application and environment
impact assessment Request for Further Information – Request Nos. 8
to 11, 16 & 19; CRP Marine consent application and environment
impact assessment REVISED Response to Request for Further
Information – Request No. 3, 4, 5 and 7; CRP Marine consent
application and environment impact assessment Response to Request
for Further Information (Request Nos. 17 and 18); submissions from
Clean Earth, Deep Sea Conservation Coalition Incorporated, Iwi
Collective Partnership, McCrone A, KASM, HMT, Havemann P,
Swapkomund Matters, Te Runanga o Ngai Tahu, and The Crown;
Statement of evidence of Paul Cameron Kennedy for Chatham Rock
Phosphate Limited on sediment and chemistry, 29 August 2014; EPA
Staff Report EEZ000006 Chatham Rock Phosphate Limited Marine
Consent Application August 2014; and
(b)
Relevant published science literature.
Louis Tremblay
12 September 2014
3
ANNEXURE A
1. A critical appraisal of potential ecotoxicological effects on the environment
associated with the Chatham Rock Phosphate Ltd (CRP) marine consent
application
1
A CRITICAL APPRAISAL OF POTENTIAL
ECOTOXICOLOGICAL EFFECTS ON THE
ENVIRONMENT ASSOCIATED WITH THE
CHATHAM ROCK PHOSPHATE Ltd (CRP)
MARINE CONSENT APPLICATION
Date: 15 September 2014
Louis Tremblay
2
Table of Contents
Table of Contents ................................................................................................................................... 2
Introduction ............................................................................................................................................ 3
Description of existing environment ............................................................................................... 3
Assessment of potential effects ........................................................................................................... 4
Risk of metals ................................................................................................................................ 4
Recalculations of metals resuspension and bioaccumulation ....................................................... 6
Mitigation of effects ...................................................................................................................... 10
Discussion ............................................................................................................................................ 11
Conclusions .......................................................................................................................................... 12
References ............................................................................................................................................ 13
3
Introduction
1.
Chatham Rock Phosphate Limited (CRP) submitted an application with the Environmental
Protection Authority (EPA) for a 35 year term marine consent to mine phosphate nodules from
2
the Chatham Rise. CRP would mine approximately 30 km of seabed per annum resulting in
2
about 450 km of seabed mined on the Rise in the initial 15 years of operation.
2.
The proposed mining methodology involves collecting sediment from the seabed with a trailing
suction drag-head to a vessel where the phosphorite-bearing material will be mechanically
processed.The resulting tailings material will be returned to the seabed through a flexible hose.
3.
The aim of this report was to provide a critical appraisal of the potential ecotoxicological effects
of the proposed mining activities on the receiving environment. The main objectives were to: 1)
assess the scale and significance of potential ecotoxicological effects on receptor species and
ecosystems as a consequence of the extraction of sediment and deposition of tailings; 2)
evaluate whether any marine species could be exposed to toxic levels of contaminants
exceeding trigger levels of effect; 3) a brief discussion on whether the best available information
and modelling outputs have been used to assess ecotoxicological effects and whether
uncertainty or inadequacy remains; and 4) identify mitigation measures considered to be
necessary to ensure acceptable levels of effects are achieved and maintained.
4.
This review focussed on the CRP application reports with information of relevance to
ecotoxicology including: the CRP EIA application and relevant appendices, the applicant’s
evidence reports, the CRP reports in response to further information requests, the external
submissions and the EPA staff report.
Description of existing environment
5. Section 6 of the CRP EIA describes the Chatham Rise as an area of high productivity
supporting a rich ecosystem. There are spawning grounds and nurseries for commercial fish
species. Those are receptor species that would potentially be exposed to stressors resulting
from the proposed mining activities.
6. It is worth noting that the waters in the Chatham Rise are stratified and the temperature and
salinity decrease with water depth and vary seasonally. This is an important characteristic as
these gradients influence geochemical characteristics of the water column and can modulate
metal speciation and their toxicity.
4
Assessment of potential effects
7. The CRP EIA used an environmental risk matrix to rank the severity of the risk of the impacts
associated with the general operations including seabed disturbance from drag-head
operations. The physical and cumulative impacts of the disposal of the tailings and their effects
on water and sediment quality and ecosystems health were ranked from low to serious (Table
19 of the EIA). The CRP EIA concluded that the physical impacts from the proposed mining
activities are considered minor and would be minor.
8. The main toxicological risk when processed sediment and nodule particles are returned to the
bottom water layer is whether the deep-sea ecosystem might be influenced by the potential
effects of heavy metal release and/or binding (Koschinsky et al. 2003a). Metals are the key
stressors as CRP application states that no chemicals will be used in the separation of the
coarse phosphatic material from the finer non-phosphatic sediments. The ecotoxicological risks
would be the: 1) destruction of the ecosystems and its functions from the sediment extraction; 2)
return of the tailings to the seabed and; 3) potential release of metals from the oxic and suboxic
sediment layers.
9. The sediments that host the phosphorite deposit on the Chatham Rise are glauconitic, fine to
medium grained sandy muds and muddy sands. Concentrations of most trace elements are
higher in finer, and lower in coarser sediments. The deep sea sediment geochemical
characteristics influence the distribution of metals and their bioavailability. The best available
information about the distribution of metals in deepsea environments is based on studies in the
Southeast Pacific Peru Basin (Thiel 2001). The oxic pore water exhibits relatively small values
of dissolved Mn and other heavy metals with concentrations in the µg/L range. Metals are
strongly scavenged on Mn oxide or Fe oxyhydroxide particles reducing their bioavailability
(Koschinsky et al. 2003b). In the suboxic layers, dissolved Mn concentrations increase by
several orders of magnitude into the mg/L range and dissolved metals related to Mn, such as Ni,
Co, Zn, Cu, Pb, Cd, and Tl may occur in higher concentrations (Thiel 2001).
Risk of metals
10. The CRP EIA recognises that the proposed mining activities would impact the various
components of the environment as summarised in Section 8.13. CRP EIA estimates that the
potential impacts and environmental risks to water and sediment would be minor.
11. The two main databases used to assess the risk of metals in sediments or the water column are
the Australian and New Zealand Environment Conservation Council (ANZECC) water quality
guidelines (ANZECC 2000) and the European Chemicals Agency guidelines (ECHA 2008). The
5
effects of a substance on the environment are quantitatively assessed by calculating the
concentration of the substance below which adverse effects in the environmental sphere of
concern are not expected to occur. This concentration is known as the Predicted No-Effect
Concentration (PNEC). This is an important step in the ecological risk assessment of chemicals
is determination of the maximum concentration at which the ecosystem is protected. That is, the
predicted no-effect concentration (PNEC). PNECs are usually derived for a limited number of
species in laboratory-based toxicity tests which have well-defined protocols. In New
Zealand/Australia, species sensitivity distributions (SSDs) and protective concentrations for 95%
(PC95) of local species are being used to derive water-quality guidelines for toxicant (Jin et al.
2012).
12. The Golder (Appendix 11 - 2014) Review of Sediment Chemistry and Effects of Mining report
concludes that “the potential for toxicity related to trace element release due to mining is very
low”. None of the metals measured in sediment (chalk and non-chalk) presented in Table 8
(CRP Ltd 2014) exceed the ANZECC Interim Sediment Quality Guidelines (ISQG) –Low, a
trigger value representing a concentration below which there is a low probability of biological
effects (ANZECC 2000). For nickel, the Golder sediment chemistry report states: “Nickel
abundances approached the ANZECC ISQG-Low guideline value in all sediment types (21
mg/kg). However, it should be noted that the sediment quality guidance provided in ANZECC
(2000) does not assume that concentrations above the guidance (the ISQG-Low) in natural
sediments will cause chronic (or acute) effects especially where the element has a natural
geological origin” (CRP Ltd 2014). This is valid for the current sediment and ecosystems but
may no longer be accurate once the sediment surface has been disturbed and totally modified
including the resuspension of metals. For instance, in a Southeast Pacific experimental area,
community structure was still disturbed as indicated by irregular species distributions seven
years after the excavation (Thiel 2001).
13. The risks of metal leaching from surface, sub-surface sediments and chalk were assessed by
elutriate experiments to estimate the potential ecotoxicological impacts of the proposed mining
activities. Some of the metal concentrations in sediment and chalk sample elutriates exceeded
ANZECC trigger and PNEC (chronic) values meaning they could pose a risk to exposed marine
species (Table 1).
6
14. Table 1. Concentrations of trace elements found in sediment elutriate samples from table 3 in
1
(Kennedy 2014) reported against the marine ANZECC and European PNEC guidelines for the
trace elements of concern.
Metal
Surface
Tranquil Image
Sub-surface
(in μg/L)
sediment
surface
sediment
Chalk
sediment
ANZECC
PNEC
(99%
(chronic)
protection)
Arsenic
<4-6
<4
11-24
<4 -11
2.3 – 4.5
Cadmium
<0.2-0.6
<0.2
0.5-1.7
0.7-2.1
0.7
†
0.44
0.21
†
Cobalt
<0.6-1.2
<0.6
<0.6-1.1
0.07-3
1
Copper
<1-1.5
3.2-3.7
<1-3.1
<1-1.7
0.3
0.8
Nickel
8-11
<6-8
9-13
11-20
7
8.6*
Uranium
7.7-29
10.8-14.6
48-120
30-120
NG
NG
†
0.1
95% protection; *environmental quality standard; NG no guideline values.
15. The elutriate samples used for toxicity testing summarised in Tables 3-3 and 3-4 (NIWA report
in Statement of evidence of Paul Cameron Kennedy for Chatham Rock Phosphate Limited on
sediment and chemistry, 29 August 2014) showed little increase in dissolved trace metals
concentration between 30 min and 24 hr elutriation indicating metals are stabilised on particles.
The ecotoxicological tests strongly demonstrate that the toxicity is negligible in the 3 model
species used. The amphipod test showed some toxicity in 30 min PB1, a sample from 2011
(sampling date and depth not provided). There is no explanation for not conducting the
amphipod test with the 24 hr elutriate PB1 sample. However, the most sensitive test used
(highest sensitivity to the reference toxicants) is the blue mussel embryo-larval assay that
showed no effects in any of the elutriate extracts. This is a strong indication that the risk are
negligible as the test is based on the early life-stages (ELS) that are usually the most sensitive
(McKim 1977; Belanger et al. 2010)
Recalculations of metals resuspension and bioaccumulation
16. In an attempt to better estimate the potential release of metals from the sediment pore water to
enter the bottom water when the surface sediment layer (including the suboxic pore water) is
suspended, a calculation used for the Southeast Pacific Peru Basin was applied using the data
from the Chatham Rise (Koschinsky et al. 2003b). In brief, the following equation was used to
calculate the possible concentration of a resuspended metal (MR) in μg/L:
1
http://echa.europa.eu/
7
17. [M]R = (D1  RPW1  [M]PW1 + D2  RPW2  [M]PW2 + B  Ms)/(B+D1+D2)
where:
1: in the oxic zone
2: in the suboxic zone
D: depth of the layer (cm) (D1: 10.5 cm, D2: 39.5 cm)
RPW : ratio pore water/sediment (60%)
PW: pore water
B: bottom water layer (50cm)
[M]: metal concentration (μg/L)
(R: resuspended, S: in seawater)
18. The parameters used were 1) the proposed total depth of mined sediment of 50 cm devided
between 2) the depth of the oxic zone observed (10.5 cm) (CRP Ltd 2014) and 3) the remaining
sediment as the suboxic zone but excluding the chalk bedrock. Chalk is not included as the
drag-head is designed to avoid dredging the underlying chalk layer (section 4.4.4 of the CRP
EIA report). The metal concentrations used for the pore water of the oxic ([M]PW1) was from the
surface sediment elutriates and the metal concentrations for the suboxic zone ([M]PW2) was from
the sub-surface sediment elutriates. The results of these new calculations are summarised in
Figure 1. Only copper concentrations estimates are above the ANZECC trigger value. However,
the calculations are based on assumptions (depth of oxic and suboxic zones, pore water metal
concentrations in oxic and suboxic zones, and sediment pore water ratios) that may not reflect
actual conditions in the Chatham Rise sediment.
8
19. Figure 1.
Estimated metal concentrations in the water column following re-suspension of the
sediment. The circle diameters with value above indicate the ratio compared to ambient
seawater. The respective ANZECC guidelines are in parenthesis when available.
(80)
9.7
Concentrations (ug/L)
34
32
30
28
26
8
(7)
6
(4.5)
4
0.7
8.1
2
8.9
0.7)
(0
0
As
Cd
2.5
2.4
(0.3)
Cu
Mn
Ni
U
20. Disturbance experiments using fresh sediment cores with high particle concentrations in the
suspension showed that initially elevated dissolved metals concentrations decreased close to
normal background values within the first hour (Koschinsky et al. 2003b). It is likely that
dissolved heavy metals released from pore water or particles into the system will be scavenged
by manganese oxides and the particles resuspended in comparatively high concentrations
(Koschinsky et al. 2003a). Therefore, the impact of the release of metals into the water column
is likely to be of short duration.
21. Bioaccumulation factor (BAF) is the ratio of a chemical concentration in an organism to the
concentration in water resulting from all possible routes of exposure (e.g., dietary absorption,
transport across the respiratory surface). BAFs for cadmium, copper, zinc, chromium and
arsenic (and mercury for comparison) for a range of marine organisms (zooplankton, molluscs,
crustaceans and fish) (DeForest et al. 2007) are summarised in Figure 2.
9
22. Figure 2. Empirical bioconcentration factors (BAFs) (minimum, maximum and geometrical
mean) in saltwater animals. Source (DeForest et al. 2007)
10
8
40666667
10
8100000
7
3899000
Bioaccumulation factors
106
680000
105
260633
57094
26866
10
10
4
5200
3
1999
61129
26016
27666
10808
1423
411
10
299
157
2
65
10
1
Cr
As
Cu
Cd
Zn
Hg
23. The mean BAFs from Figure 2 were used to calculate the potential concentrations in exposed
organisms of three metals that were over the ANZECC trigger values in the surface and subsurface elutriate samples (Table 1). Estimated tissue metal concentration (mg/kg dry weight) =
water concentration (µg/L)  BAF  0.001 (DeForest et al. 2007).
24. Table 1.
Potential concentration of metals in organisms from the re-suspension of metals (from
elutriate sample highest concentrations measured in surface or sub-surface sediment).
Elutriates
(μg/L)
Arsenic
Cadmium
Copper
24
1.7
3.7
Potential organism
concentration
mean and range (mg/kg)
259 (34-645)
47 (0.11-1156)
96 (0.6-150467)
10
The values reported in Table 1 should be considered with caution as they are derived from the
elutriate metal concentrations that may not fully represent the metal distributions in the Chatham
Rise sediment. The estimated concentration means are below published wildlife cadmium and
copper thresholds so represent negligible risk (DeForest et al. 2007). There are many factors
influencing BAF for metal; they may be influenced equally by the exposure concentration and
species-specific factors. This may explain the extreme widespread of the concentration ranges
over orders of magnitude in Table 1, calculated from Figure 1, is due to organisms (algae to
vertebrates) accumulating metals at different rates. The arsenic concentration estimate is in the
range of what has been reported in the literature for marine fish and invertebrate species
(Meador et al. 2004). The major fraction of the total arsenic burden in many marine animals,
including fish, crustaceans and molluscs, is generally present as arsenobetaine, a stable
organoarsenic compound considered to be non-toxic. In molluscs and crustaceans, total arsenic
concentrations are generally higher than those in marine fish (Phillips 1990). In particular,
sponges are likely organisms to accumulate the most metal. They have BAF of about 5-7 orders
of magnitude higher than the level in ambient water (Patel et al. 1985; Hansen et al. 1995). This
species have been suggested as a suitable bioindicator of metal and would provide information
on levels of metals available over time.
Mitigation of effects
25. Dilution model at 10 m above the seabed predicts a dilution of at least 200 which would reduce
the concentrations of metals to non-toxic levels (Request for Further Information Requests Nos.
8-11 16, 19, July 2014). Although, metal concentrations might decrease below guideline trigger
values, there are still potential risks for long-term effects in organisms exposed to multiple
metals at sub-lethal concentrations.
26. The release of metals from pore water and from easily mobilisable metal components of the
particulate phase will be determined by strong sorption processes effective within a few hours
under oxic conditions. These processes involve manganese oxides that are very effective
scavengers specifically for cationic metals such as Ni, Co, Zn, Cu, Pb, Cd, and Tl, whereas iron
oxyhydroxide sorbs well with the oxyanions of Mo, V, and As. The mitigation should ensure that
the physico-chemical conditions are kept as closely as possible to optimum levels in order to
minimise solubilisation of metals and avoid toxicity effects (Koschinsky et al. 2003b; Koschinsky
et al. 2003a).
11
Discussion
27. The total destruction of the seabed habitats and ecosystems may reduce their ability to cope
with stresses like metals as there is limited information to accurately assess leaching rates from
the extraction and redeposition of the sediment material. As the physico-chemical conditions of
the processed sediment would likely be altered, it could modify metal leaching rates.
28. The Further Information Request report on Chemistry toxicity states that toxicity is temperature
dependant and will decrease with depth due to lower temperatures. This statement is not fully
substantiated in the literature. There is some evidence that higher temperatures have the
potential to increase the sensitivity of aquatic animals to heavy metals in their environment
(Khan et al. 2006). However, a recent study showed that the toxicity is lowest at the animal’s
optimal living temperature and increases with temperatures above or below optimum (Zhou et
al. in press). The ANZECC water quality guidelines (ANZECC, 2000) framework uses an
approach where trigger values are used to initiate more in-depth toxicity assessment using
species relevant to the studied ecosystem. There is no data on the sensitivity of key receptor
species in the Chatham Rise which introduces uncertainty for assessing the risk to this unique
ecosystem. This general knowledge gap on the ecology of the deep-sea fauna, species
densities and distributions, taxonomy, and genetic relationships within and between populations
limits the possibilities for predicting effects on the fauna (Thiel 2001).
29. In addition, the results of the NIWA ecotoxicity tests of the elutriate samples have limitations for
assessing the risk to local species for the Chatham Rise. The tests used were mostly acute
(short-term) with the exception of the bacterial test. The data have limited ability to predict
potential long-term sub-lethal chronic effects. Plus, the tested elutriate samples were produced
from frozen sediment which can modulate the toxicity and introduce a bias (Geffard et al. 2004).
30. The metals may be found at concentrations below guideline trigger values but are likely to be in
mixtures. This situation could be maintained or deteriorate over the 35 year period and lead to
multi-generational effects on exposed populations. The uncertainty of the adequacy of using
ANZECC (2000) guideline levels to protect species at the proposed depths in the marine
environment is raised by the EPA Staff Report (EPA 2014). This is a valid point as the ANZECC
are guidelines based on single chemicals and do not take into account multiple stressors. It is
likely that the ecosystem could be under high pressure from the multiple metals and other
stressors like sediment during the recovery period following redeposition of the tailings. For
instance, a recent study in the Tauranga Harbour measured copper, zinc and lead
concentrations and soft-sediment benthic community composition. A multivariate analysis of the
data revealed community level effects at contaminant levels below guideline threshold values
(Tremblay et al. submitted).
12
31. Mining of metalliferous resources from the deep sea such as the CRP proposed mining activities
are recognised for the unpredictable and inadequately assessed environmental impacts (Thiel
2001). A robust evaluation of the environmental impacts would require a thorough monitoring
and characterisation of a future mining operation at the pilot scale (Thiel 2001). The monitoring
programme of sediment risk assessment must include chemistry, biomagnification potential,
sediment toxicity and benthos alteration (Chapman & Smith 2012).
Conclusions
32. This appraisal of the potential ecotoxicological impacts estimates that the risks from the release
of sediment metals from the CRP proposed mining activities are minor based on the provided
dataset. Following the recalculation of metals released and estimation of bioaccumulation, the
risk can be classified as low. This confirms the CRP EIA estimation that the proposed mining
activities would lead to low to medium environmental risks. However, potential long-term and
multi-generational effects cannot be ruled out during the recolonization phase of the disturbed
mined area. Ideally, preliminary information could be collated from a small pilot scale study to
generate data relevant to the Chatham Rise environment that would be more appropriate to
assess the risk of the full scale operation. This would validate the assumptions used to assess
the risk of metals to the local ecosystems and the information could be integrated into the
proposed adaptive management framework.
13
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