Bitumen in Nigeria: Weighing The True Costs of Extraction
Bitumen in Nigeria: Weighing The True Costs of Extraction
Bitumen in Nigeria: Weighing The True Costs of Extraction
IN NIGERIA
Weighing the True Costs
of Extraction
2 3
The Future of Bitumen in Nigeria
Nigeria’s bitumen, also known as oil sands, has not yet Fig. 2: Three Different Methods of Bitumen Extraction
been exploited, but is a potential source of future revenue 1. SMALL - SCALE 2. LARGE - SCALE 2. IN-SITU
SURFACE MINING SURFACE MINING EXTRACTION
for Nigeria. Though the social and environmental impacts
of bitumen exploitation are anticipated to be serious and Bitumen Depth ~0-20m 0 - 75m 75 - 400m
determines which extraction method(s)
widespread, there is limited public understanding of what can be used
exactly Nigerians can expect during and after development.
Bitumen and extra-heavy oils are un- out this publication, Canada is used as a name, oil sands. The bitumen must be
conventional oils that generally require reference point for understanding what removed from the sands and processed Fig. 3: Oil Types Found in Nigeria
additional processing to extract, trans- the impacts of bitumen development in before it can be refined like conven-
port, and refine into petroleum products Nigeria could be. tional oil. Unlike the light, sweet crude CONVENTIONAL OIL
Light and fluid, presently found in
than lighter, conventional oils. These This publication seeks to raise aware- found in the Niger Delta, extra-heavy oil the Niger Delta region
additional steps typically incur addition- ness of the potential impacts of Nige- and bitumen are viscous and dense. To
al costs - including investment costs as rian bitumen development, and asks two convert this tar-like substance into light- Light Crude
well as environmental and social costs. questions : (1) Is it truly in the best future er oil, called synthetic crude, that can 37 billion barrels of crude oil
in proven reserves, currently in
As conventional oil reserves decline, in- interests of Nigeria to exploit bitumen? be used for petroleum products such as production
ternational companies are increasingly (2) If so, can Nigeria avoid repeating petrol, the bitumen must be removed
turning their attention towards uncon- the mistakes made during oil develop- from the sands and processed. Figure Heavy Oil
Unknown reserves, exploration
ventional oils to meet rising global de- ment in the Niger Delta? The intent of 3, right, provides an overview of Nige- has found evidence of poten-
mand for petroleum products. the publication is not to directly answer ria’s different types of oil, ranging from tial
Nigeria has an estimated 38 billion bar- either question. Instead, the publica- heavier unconventional oils to the light
rels of extra-heavy oil and bitumen re- tion aims to inform stakeholders of the ‘sweet’ crude found in the Niger Delta. Extra Heavy Oil
potential impacts of bitumen develop- Unknown reserves, explora-
serves. While this amount is significant, tion has found evidence of po-
and roughly equivalent to its present ment. As Nigeria is looking beyond con- How is bitumen extracted? tential
conventional oil reserves, this amount ventional oil production, it is an ideal Nigeria’s former Ministry of Mines
Fig. 1: Top 10 Countries with Bitumen and is much, much smaller than Canada’s time to reflect on the full range of im- and Steel Development has identified Bitumen/Oil Sands
Extra-Heavy Oil Reserves. Nigeria ranks #6 2.4 trillion barrels and Venezuela’s 2.1 pacts of development before reaching a three potential methods of bitumen Estimated 38 billion barrels of
globally in heavy oil and bitumen reserves, extraction in Nigeria: (1) small-scale oil, unknown when/if produc-
with an estimated 38 billion barrels of oil trillion barrels1, as shown in Figure 1, final decision. tion will commence
in place. While this remains a significant left. Geologists and engineers predict surface mining (2) large-scale surface
quantity of oil, it is substantially less than that Nigeria would use similar methods What is bitumen? mining and (3) in-situ extraction (see
Canada and Venezuela, who hold the num- UNCONVENTIONAL OIL
to extract bitumen as Canada, as the re- Bitumen is typically found surround- Figure 2). The depth of bitumen below Heavy and solid or semi-solid, re-
ber one and two spots, respectively.
serves are geologically similar. Though- ing sand grains encased in water and the surface determines which extraction quires additional energy and steps to
type is possible. Both in-situ and large- process
clay, which is where it gets its alternative
1 USGS 2010 scale surface mining operations are most
4 5
Small-Scale Surface Mining
Small-scale surface mining could transform Nigeria's land- KEY ENVIRONMENTAL IMPACTS
scape into a network of active and abandoned mining pits.
Small-scale surface mining is one of at the surface would be the most likely
three major extraction methods identi- location for smaller scale mines. Many Greenhouse Contamination Topsoil
fied by Nigeria’s Ministry of Mines and of these communities are already aware Gas Emissions /Oil Spill Disturbance
Steel Development that could be em- of their bitumen resources, due both to
Un
co
ployed for bitumen extraction in Nige- the visible bitumen at the surface as well
nv
en ria. This method would be used in plac- as previous studies and tests carried out
tio es where bitumen is close to the surface, within the communities.
na Water Water Air
l at depths of 0-20m. Of all three bitumen extraction sce-
50 km Usage Pollution Pollution
Small-scale surface mining requires narios, the least is known about the
Co
nv
en
the removal of all ‘overburden’, or veg- potential impacts and processes of
tio
na etation and soil above the bitumen layer. small-scale mining. Depending on the
l Though extraction operations are ex- infrastructure and investment in the Vegetation + Vegetation + Habitat
pected to vary by location and operator, mining operations, the size and number Habitat Loss Fragmentation
bitumen removal would most likely oc- of pits could vary tremendously, in turn
cur using trucks and shovels in a network altering the scale of environmental im- Anticipated environmental impacts are
Fig. 4: Nigeria’s Bitumen Belt. Bitumen is likely to extract bitumen for upgrading of smaller pits. The bitumen would be pacts. Impacts shown here were based shown above, ranked across the three
found across Lagos, Ogun, Ondo, and Edo
into synthetic crude oil and/or other pe- The Impacts of Extraction transferred via road to processing facili- on examples of small-scale mining pits types of extraction from ‘high’ (red), to
States. Blocks A, B, and C, were first bid on
in 2009. troleum products. Bitumen from small- All three types of extraction, (1)small- ties, where they could be used as a major for other solid mineral mines. ‘medium’ (orange), to ‘low’ (yellow).
scale surface mining is likely to only be scale surface mining (2) large-scale sur- component of road asphalt.
economical to use for paving roads. All face mining and (3)in-situ sub-surface Communities with bitumen visible
three types of extraction are described mining have serious impacts, but these
in greater detail in the next sections. impacts vary widely. For example, while Affected Communities Overburden Abandoned Pits
In Nigeria, the approximate locations surface mining completely transforms Open pit mines, even if they re- Overburden, or the vegetation Abandoned, unreclaimed pits pose numer-
of the different types of oil are per- the entire surface of the mining area, main small, alter the topography and soil that are removed to ac- ous dangers to nearby residents. As the
haps best explained as a gradient run- in-situ sub-surface extraction mostly and drainage patterns of the cess bitumen below the surface, pits fill with water, the standing water can be
ning north to south, with the heaviest takes place underground. Following this landscape. This can pollute local must be removed and stored a breeding ground for mosquitos or water-
oils generally in the north at the surface section, each method of extraction and streams and contribute to flooding properly. Failure to do so means borne illness. Unstable slopes can cause pit
in adjacent communities. the soil may lose productiv- walls to collapse during heavy rains. Pits filled
and the lightest in the south deep un- the associated impacts are described
ity. with water also pose a drowning risk to small
derground (see Figure 4). The bitumen in greater detail to help decision mak- children.
region spans roughly four states - in- ers understand which method, if any,
cluding Lagos, Ogun, Ondo, and Edo should be permitted in Nigeria.
states. Much of the area where heavier Most environmental impacts will
forms of oil and bitumen can be found directly affect land-based livelihoods
remain underexplored, so the precise lo- throughout Nigeria’s bitumen belt. For
cations of each resource are unknown. each type of extraction, impacts are
The most comprehensive bitumen study ranked from ‘HIGH’, or large-scale,
to date is Geotechnical Investigations of the significant impact to ‘LOW’, or smaller-
Ondo State Bituminous Sands from 1974, scale, moderate impact (see Figure 5).
and was led by Professor O.S. Adegoke To date, Canada is the only country to
of the Geological Consultancy Unit of exploit its bitumen resources on a wide-
the University of Ife. Few significant spread scale. For this reason, average
studies have been carried out since. The impacts of Canadian bitumen projects
Fig. 5: Environmen- extents shown on the map in Figure 4, are referenced throughout this brief in
tal Impact Ranking. above, identify the zones where surface an attempt to gauge the potential en-
In the following sec-
mining and in-situ mining are most like- vironmental impacts of the industry in
tions, key environ-
mental impacts are ly to occur, according to Adegoke’s and Nigeria. While bitumen development
loosely ranked from subsequent exploration work. Some ge- may bring many economic benefits,
‘high’ (red), to me-
dium (orange), to
ologists speculate this zone extends all learning from the Canadian experience
‘low’ (yellow). the way to the conventional oil blocks helps us to anticipate what environmen-
further south. tal impacts Nigeria could expect if bitu-
6 7
Large-Scale Surface Mining
Large-scale surface mining could transform vast areas of Fig. 6: From Exploration to Production: the Large-Scale Surface Mining Process
KEY ENVIRONMENTAL IMPACTS
Nigeria's landscape into mining pits and tailings ponds.
The first step of large-scale surface energy required to separate and upgrade
mining requires the removal of all ‘over- the bitumen into synthetic crude oil,
Greenhouse Contamination Topsoil burden’, or vegetation and soil above the producing one barrel of oil from bitu-
Gas Emissions /Oil Spill Disturbance oil sands layer 0-75m from the surface. men emits 3.2-4.5 times the amount of
The bituminous sands are mined using greenhouse gases as conventional oil.†
huge shovels and trucks and transport- Of all three methods of extraction, 1. Exploration
ed to a plant to separate the bitumen large-scale surface mining most com- During the exploration phase, a gridded
Water Water Air from the sand. A specialized hot water pletely transforms the surface of the network of cutlines is used by seismic
Usage Pollution Pollution extraction process is used to create a landscape. Figure 5, on the opposite sounding trucks to determine the depths of
slurry of bituminous sands and water, page, describes the process of mining oil sands below the surface. At key loca-
which is then processed so the bitumen bitumen from exploration to process- tions, test well pads are also cleared and
rises to the surface out of the sands. ing and transportation. Reclamation of used to drill test wells that help determine
Vegetation + Vegetation + Habitat Some of the water is separated out of surface mining is particularly challeng- bitumen depth with more accuracy.
Habitat Loss Fragmentation the slurry and recycled, and the remain- ing. While there are some examples of
ing clay, water, and sand, called tailings, sites that have been filled in and planted,
Anticipated environmental impacts are are transported to on-site tailings ponds. the bitumen industry in Canada is still
shown above, ranked across the three The bitumen is transported to the up- so new that it is unknown if these highly
types of extraction from ‘high’ (red), grading plant, where it is upgraded into disturbed sites can be reclaimed as vi-
to ‘medium’ (orange), to ‘low’ (yellow). synthetic crude oil that can be sent to able sites for wildlife or other uses.
refineries. Due in large part to the extra
2. Construction
Preparing the site so mining can begin
requires removing overburden, or topsoil,
Water Usage Mining Pits Tailings Ponds from areas that will be mined. In addition,
In Canada’s bitumen mining sites, Before mining can begin, all Tailings, a frequently toxic byproduct of bitumen facilities are built to extract the bitumen
the majority of water used in mines topsoil and vegetation must production, are stored in massive tailings ponds. from the bituminous sands and dilute it
comes from the Athabasca river. be cleared from the site. On In Canada, 1.5 barrels of tailings are produced for with other lighter substances so it can be
For every 1 barrel of bitumen average, 9.4 ha of land is dis- every barrel of bitumen.* It is unknown if these transported via pipeline for further pro-
produced, 2.1 barrels of water are turbed for every million bar- ponds can be reclaimed to a level sufficient to cessing.
extracted from freshwater sources. rels of bitumen produced.* support functional ecosystems in the future.
Most ends up in massive tailings
ponds.
3. Tailings Management
RAW WATER POND RECYCLED WATER POND Tailings are the byproducts left over after
PROCESSING PLANT & UPGRADER the bitumen is removed from the bitumi-
nous sands and sent on for processing. The
UTILITY PLANT
byproducts include significant amounts of
TAILINGS POND
MINING PIT water, and so are stored in massive tailings
ponds until heavier particles like sand settle
TAILINGS STORAGE FACILITY out from the water.
10 11
The Present-Day Landscapes of Nigeria’s Bitumen Belt
All land near or on top of Nigeria’s bitumen belt is likely to
be affected by the soil, water, and air pollution associated
with extraction. On sites where bitumen is located near the
surface, all topsoil would be removed, making farming im-
possible.
Livelihoods and landscapes of Nigeria’s As bitumen lies beneath land with existing productive, in-
bitumen belt This page and opposite show
just a few of the many livelihoods in the bi- come-generating uses, these other productive uses would “Our people are predominantly
tumen belt that rely on the land and water
resources of the area. Major occupations need to be relocated in the event of bitumen production. farmers and fishermen. They plant
include subsistence and cash-crop agri-
This section features some of the present-day landscapes in cocoa and food crops like cassava.
culture, fishing, logging, sand mining, and
more. All of these industries would be af- We know that when they start the
fected by bitumen development. (All pho- Ondo State near Okitipupa, in the heart of the bitumen belt.
tos by Christina Milos, 2014) exploration it will affect our crops. It
will affect both cash crops and food
crops. It will kill the fishes in the rivers.
It will affect our sources of livelihood.”
High Chief Adesanya of Agbabu in Odigbo Local
Government, as quoted in Before the Earth Bleeds (Ojo et
al, 2004)
12 13
The Future Landscapes of Nigeria’s Bitumen Belt?
Though Nigeria has a very different climate and a much
larger population than Canada, Canada’s extraction sites
are anticipated to look very similar to those Nigeria would
have. This section features images of Canada’s bitumen
landscapes, as a glimpse of what Nigeria’s landscape would
look like if bitumen exploitation occurs in the future.
Canada’s Bitumen Landscapes - Surface
Mining
In Canada, many of the areas used for bitumen were for- Opposite page: A site being prepared for
surface mining. Prior to digging the large
merly public lands with few people living on them that are mining pit, all topsoil, called ‘overburden’ is
removed and stored in linear piles.
leased to companies for bitumen exploitation. In Nigeria,
the area is much more densely populated and actively used, This page, top: A bitumen processing facil-
ity for surface mining is shown inthe fore-
and thus many existing land uses would be threatened. ground, and a tailings pond in the back-
ground.
14 15
Canada’s Bitumen Landscapes - In-Situ
Extraction The images on this page show
the range of patterns that bitumen explo-
ration leaves behind. Each picture shows
seismic cut lines and test well pad sites, but
on each site, the pattern is slightly differ-
ent. (All images Christina Milos 2015)
16 17
Learning from the Niger Delta Oil Industry
The United Nations Environment Programme calls the Niger
Delta “one of the most polluted places on earth”. Coated
in the oil extracted from beneath the delta, the people who
Oil Slick Many sites in the Niger Delta are
live in the watery landscapes of the Niger Delta have paid coated in slicks of oil that leave behind resi-
due on people, animals, and plants. (Image
a terrible price for the oil extracted from their lands. credit : HOMEF)
The devastation wrought by the oil industry begs a critical “The inability of the Federal
Government to formulate proactive
question of decision makers looking to develop bitumen - is
policies regarding the socio-economic
it possible to avoid the mistakes Nigeria has made in the
condition of the bitumen area will
Niger Delta? Is is possible for bitumen extraction, an indus-
inevitably lead to a replication of the
try with an arguably larger footprint than conventional oil,
avoidable violence in the Niger Delta”.
to have a less deadly impact?
High Chief Kayode Iwakun
The legacy of the Niger Delta oil way to widespread militancy, crime, and Chairman, Organisation of Bitumen Producing Areas
industry is one of pollution, corruption, kidnapping of oil workers. Today, an (OBPA)
as quoted in Before the Earth Bleeds (Ojo et al, 2004)
and unfulfilled promises. Oil producing amnesty agreement is in place, however,
communities continue to struggle with this tenuous agreement is set to expire
widespread pollution, poor health, pov- at the end of 2015, without a clear plan
erty, and conflict. for what happens next, as of the time of Gas Flare Gas flaring and fires are a com-
Oil was discovered in commercial this reports writing in December 2015. mon site in the Niger Delta - spewing heat
quantities by Shell-BP at Oloibiri in In 2011, the United Nations Envi- and air pollution into local communities.
1956. As oil revenues began to flow, ronment Programme released a report, (Image credit: Israel Aloja)
communities expected to reap its re- Environmental Assessment of Ogoniland,
wards in the form of employment, de- documenting the widespread pollution
velopment and infrastructure. While it that continues to threaten health and
is estimated that the Nigerian state has livelihoods in Ogoniland, nearly two
captured nearly 1 trillion dollars from decades after the oil industry ceased to
the oil industry1 since 1956, during that operate in the area. According to a 2014
same period an estimated two million report by Amnesty International, both
tons of oil in the form of hundreds of Shell and the Nigerian government have
spills per year has coated communities, failed to follow through on the report’s
farmlands, and fisheries in the Niger recommendations.3 The government
Delta2. In perhaps one of the starkest and oil industry have repeatedly failed
examples of the ‘resource curse’, the to fulfill promises to redress greivances
communities living in the landscapes of the Niger Delta. This toxic cycle of
producing such immense wealth live pollution, corruption, and unfulfilled
in deep poverty, rooted in widespread promises of restitution has continued
pollution that has devasted typical liveli- for over fifty years. This leads us to a
hoods such as fishing and farming. Dis- critical question - would bitumen exploi-
illusioned with the ongoing pollution tation result in a similar toxic cycle?
and corrupt patronage networks that
permeate the creeks, residents have em-
ployed numerous tactics in an effort to
seek justice. Organized protests against
oil corporations like Shell, resulting in
the military action that led to the death
of leading activists in the 1990s, gave
1. A Tale of Two Gulfs: Life, Death, and Dispos-
session Along Two Oil Frontier. Watts, Michael in
American Quarterly. September 2012. 3. No Progress: An Evaluation of the Implementation of
2. Curbing Violence in Nigeria (III): Revisiting the Niger UNEP’s Environmental Assessment of Ogoniland, Three
Delta. International Crisis Group. 2015. Years On. Amnesty International. 2014.
18 19
Should Bitumen Stay in the Ground?
While only the public and decision makers can decide if bi-
tial loss of land and livelihoods, there re- James Hansen argue that exploiting
tumen should stay in the ground, the decision to extract mains an extremely high risk communi- particularly dirty fossil fuels such as bi-
should not be taken lightly. Historically, the Nigerian gov- ties will lose their land and livelihoods to tumen will speed global climate change
bitumen development as well as fail to towards a tipping point that will trigger
ernment has failed to manage oil revenues well and also benefit from future revenue. catastrophic global impacts4.
failed to mitigate social and environmental impacts in the
The Technical Challenge Alternative Development Paths
places where oil is extracted. There is little evidence that As an industry, bitumen extraction Until dramatic improvements in gov-
this lack of governing capacity has significantly changed. in its present form is relatively new. ernance hold industries accountable for
This means that the long-term impacts their actions and ensure communities
of extraction are still being studied and are adequately compensated for land
Presently, many people living in the bitumen belt claim to are poorly understood. In Canada, com- and livelihoods lost to industrial devel-
munities living downstream from water opment, any promises that bitumen ex-
welcome bitumen development, but this may be due to a bodies polluted by bitumen waste water ploitation would yield different results
lack of knowledge of the full extent of potential impacts. have been found to have significantly than the Niger Delta ring hollow. The
higher rates of cancers, and can often no governance, technical, and global chal-
Understanding the true costs of development requires bet- longer eat the fish and animals in these lenges to bitumen development out-
ter knowledge of exactly how bitumen would transform the polluted areas. In addition, as much of lined in this final section are intended to
the land in Canada is still undergoing encourage the reader to weigh the true
massive landscape of the bitumen belt. extraction, little is known about the long costs of bitumen extraction.
term potential and expense for remedia- With such a high risk for potentially
tion of contaminated sites. In Nigeria, devastating impacts, it would be wise for
the government and oil industry strug- residents of the bitumen belt to con-
The Governance Challenge gle to remediate sites despite having the sider other potential investment paths.
Many experts agree that the prob- piecemeal efforts with little chance of technical knowledge to do so - for the Much of the bitumen belt features rich
lems of the Niger Delta oil industry having a lasting impact. The weak gov- oil sands industry, this knowledge is still farmland with great potential for ag-
reflect a failure of governance, and ernance structures currently in place for being developed. Is Nigeria, with a long riculture. Investing in farming imple-
there is little evidence to suggest bitu- oil development provide little reassur- history of failing to enforce regulations ments, inputs, infrastructure, and agro-
men development would yield a dif- ance that governance of bitumen devel- and a population who depends largely processing could help improve yields
ferent outcome. Over the years, there opment would be any different. on the health of the environment for and increase profits in the existing ag-
have been a number of failed attempts In addition to institutional dysfunc- their livelihood, really the best place for ricultural industry. In addition, the area
by the Nigerian government to redress tion, the existing legal framework gov- the oil sands industry to test out remedi- boasts rich forest resources which could
the grievances of the people of the Ni- erning the rights of Nigerians to their ation techniques which may or may not be sustainably harvested for timber pro-
ger Delta. The government has created local land and resources make it difficult be effective? duction. Finally, the bitumen belt fea-
many institutions ostensibly responsible to ensure that the people who are most tures other minerals with a much smaller
for enforcing oil industry regulations affected by resource development have a The Global Challenge extraction footprint, including ball clay,
and promoting regional development in say in the development process. Accord- With 17 percent higher greenhouse kaolin, salt, and silica. Silica is a critical
oil producing areas. These include the ing to the Land Use Decree of 1978, all gas emissions than conventional oil ex- material needed for the production of
Department of Petroleum Resources land is vested in the state. Additional traction, bitumen is often regarded as solar panels. While silica mining is still
(1970), the Niger Delta Development laws stipulate that all mineral resources, one of the dirtiest fossil fuel sources2. an extractive industry with environmen-
Commission (1999), the National Oil including oil and bitumen, fall under There is a consensus among scientists tal impacts, the footprint is significantly
Spill Detection and Response Agency federal control. The result of this legal that greenhouse gas emissions are the smaller than bitumen extraction, and it
(2006), Ministry of Niger Delta Affairs framework is that the state has the right primary drivers of climate change and could potentially support the emergence
(2008), and a number of state level to appropriate land for industrial devel- its myriad, largely negative, impacts. of a solar panel industry and Nigeria’s
development commissions. One 2007 opment, and the federal government has Nigeria is already experiencing the transition to renewable energy. These
NDDC effort much lauded by the gov- the right to the revenues derived from impacts of climate change, including suggested alternatives to bitumen devel-
ernment was the Niger Delta Regional that land, leaving little direct control to drought in northern parts of the coun- opment are just a few of the many de-
Development Master Plan (NDRD- local communities. While there are legal try and flooding in the south3. Think- velopment paths available. Regardless
MP). However, as of October 2013, provisions to compensate people whose ers such as renowned climate scientist of the path that the people of Nigeria’s
the acting managing director reported land is taken for resource development, bitumen belt embark on, it is critical that
2. Canadian Oil Sands: Life-Cycle Assessments of
that only 37% of proposed projects these compensation mechanisms have the people living in the belt are the ones
Greenhouse Gas Emissions. Congressional Research
had been completed since 20001. Dys- proved highly inadequate not only in driving the decision making process,
Service. 2014.
functional institutions like the NDDC the case of the Niger Delta, but also 3. Nigeria’s Intended Nationally Determined Con-
and only reach a decision after fully un-
often suffer from insufficient funding throughout the country when land has tribution. The Federal Government of Nigeria. in derstanding and carefully weighing the
and overlapping mandates, resulting in been claimed by the state for develop- preparation for Adoption of Climate Change Agree- true costs of bitumen extraction.
1. “Our Journey to Greatness”, NDDC News ment projects. Without adequate legal ment at the Paris Conference on Climate Change in 4. “How much will tar sands oil add to global warm-
(monthly newsletter), October 2013. protection and compensation for poten- December, 2015. ing?”. Scientific American. January 23, 2013.
20 21
This is a clarion call for the respect of the
primacy of the interests of local people for
a sustainable Nigerian environment. We all
know what has become of the Niger Delta.
We all know what has become of the tin
mines of Jos. The people must weigh in a
balance what they stand to gain from ex-
ploitation or non-exploitation of resources
in the environment. And the people are the
ones who must make the decisions.
-Nnimmo Bassey, in “Before the Earth Bleeds Again”
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