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{{#Wiki_filter:X-energy  
{{#Wiki_filter:X-energy January 16, 2018 Ms. Amy Cubbage U.S. Nuclear Regulatory  
January 16, 2018 Ms. Amy Cubbage U.S. Nuclear Regulatory  
Commission  
Commission  
ATIN: Document  
ATIN: Document Control Desk Washington, D.C. 20555-0001  
Control Desk Washington,  
Subject: UPDATED DESIGN AND LICENSING  
D.C. 20555-0001  
Subject:  
UPDATED DESIGN AND LICENSING  
SUBMITIAL  
SUBMITIAL  
INFORMATION  
INFORMATION  
Line 35: Line 31:
APPLICATIONS  
APPLICATIONS  
FOR LIGHT-WATER  
FOR LIGHT-WATER  
REACTORS  
REACTORS AND NON-LIGHT-WATER  
AND NON-LIGHT-WATER  
REACTORS X Energy, LLC 7701 Greenbelt  
REACTORS  
Road Suite 320 Greenbelt, MD 20770 +1301-358-5600  
X Energy, LLC 7701 Greenbelt  
Road Suite 320 Greenbelt,  
MD 20770 +1301-358-5600  
XEOO-R-Rl-RD-L-000027  
XEOO-R-Rl-RD-L-000027  
The purpose of this letter is to submit responses  
The purpose of this letter is to submit responses  
Line 46: Line 39:
Issue Summary (RIS) 2017-08 on behalf of X Energy, LLC (''X-energy").  
Issue Summary (RIS) 2017-08 on behalf of X Energy, LLC (''X-energy").  
This submission  
This submission  
also updates the prior X-energy  
also updates the prior X-energy submitted  
submitted  
responses  
responses  
to RIS 2015-07 (response  
to RIS 2015-07 (response  
dated November  
dated November 23, 2015) and RIS 2013-18 (response  
23, 2015) and RIS 2013-18 (response  
dated March 28, 2014). X-energy is a private, wholly-owned  
dated March 28, 2014). X-energy  
U.S. company that is pursuing the commercialization  
is a private,  
of an advanced high temperature  
wholly-owned  
U.S. company that is pursuing  
the commercialization  
of an advanced  
high temperature  
gas-cooled  
gas-cooled  
pebble bed reactor (HTGR), designated  
pebble bed reactor (HTGR), designated  
as Xe-100 (X-energy  
as Xe-100 (X-energy  
200 MWt), using U.S.-developed  
200 MWt), using U.S.-developed  
uranium oxicarbide  
uranium oxicarbide (UCO) TRISO-coated  
(UCO) TRISO-coated  
particle fuel, in conjunction  
particle  
fuel, in conjunction  
with NRC approval.  
with NRC approval.  
X-energy's  
X-energy's  
design approach  
design approach leverages  
leverages  
over 50 years of research, proven design, and operational  
over 50 years of research,  
proven design, and operational  
experience  
experience  
in HTGR using a pebble bed architecture.  
in HTGR using a pebble bed architecture.  
In addition  
In addition to developing  
to developing  
the design of the Xe-100 pebble bed reactor, X-energy, through a US DOE cooperative  
the design of the Xe-100 pebble bed reactor,  
agreement, is actively fabricating  
X-energy,  
UCO based kernels, TRISO particles, and spherical  
through a US DOE cooperative  
pebble fuel elements in a well-equipped, X-energy operated facility at the Oak Ridge National Laboratory (ORNL). In the future, this work in TRISO-based  
agreement,  
fuel element production (referred  
is actively  
to as our "TRISO-X" program) will be spun off into a separate fuel fabrication  
fabricating  
UCO based kernels,  
TRISO particles,  
and spherical  
pebble fuel elements  
in a well-equipped,  
X-energy  
operated  
facility  
at the Oak Ridge National  
Laboratory  
(ORNL). In the future, this work in TRISO-based  
fuel element production  
(referred  
to as our "TRISO-X"  
program)  
will be spun off into a separate  
fuel fabrication  
company that will ultimately  
company that will ultimately  
provide fuel for all UCO TRISO-based  
provide fuel for all UCO TRISO-based  
reactor designs,  
reactor designs, which may include some Accident Tolerant Fuel (ATF) designs applicable  
which may include some Accident  
to the existing fleet of light water reactors.  
Tolerant  
Fuel (ATF) designs applicable  
to the existing  
fleet of light water reactors.  
The Xe-100 design and TRISO fuel manufacturing  
The Xe-100 design and TRISO fuel manufacturing  
are well aligned with, and leverage,  
are well aligned with, and leverage, the Department  
the Department  
of Energy's (DOE) Next Generation  
of Energy's  
Nuclear Plant (NGNP) and Advanced Gas Reactor (AGR) fuel qualification  
(DOE) Next Generation  
initiatives, _with the fuel qualification  
Nuclear Plant (NGNP) and Advanced  
Gas Reactor (AGR) fuel qualification  
initiatives,  
_with the fuel qualification  
program established  
program established  
as the number 1 priority  
as the number 1 priority by the Energy Policy Act of 2005 (EPACT2005).  
by the Energy Policy Act of 2005 (EPACT2005).  
In fact, the on-going TR ISO-based  
In fact, the on-going  
TR ISO-based  
fuel fabrication  
fuel fabrication  
activities  
activities  
Line 128: Line 83:
used to produce AGR qualification  
used to produce AGR qualification  
test articles.  
test articles.  
The Xe-100 utilizes  
The Xe-100 utilizes intrinsically  
intrinsically  
safe features with a simplified  
safe features  
plant design to assure enhanced safety and security.  
with a simplified  
Furthermore, the Xe-100 offers several inherent features reducing proliferation  
plant design to assure enhanced  
safety and security.  
Furthermore,  
the Xe-100 offers several inherent  
features  
reducing  
proliferation  
risks and, with the potential  
risks and, with the potential  
to utilize a future thorium-based  
to utilize a future thorium-based  
fuel cycle, has the capacity  
fuel cycle, has the capacity to recycle spent fuel and reduce current stockpiles  
to recycle spent fuel and reduce current stockpiles  
of plutonium  
of plutonium  
with the very high burn-ups  
with the very high burn-ups inherent to the Thorium fuel cycle. X-energy has no affiliation, official or otherwise, with any other company working on the pebble bed approach to HTGRs. X-energy is U.S.-owned  
inherent  
and operates out of facilities  
to the Thorium fuel cycle. X-energy  
in Greenbelt, Maryland and Oak Ridge, Tennessee.  
has no affiliation,  
official  
or otherwise,  
with any other company working on the pebble bed approach  
to HTGRs. X-energy  
is U.S.-owned  
and operates  
out of facilities  
in Greenbelt,  
Maryland  
and Oak Ridge, Tennessee.  
MD O:) y&ol {\) f_ 0   
MD O:) y&ol {\) f_ 0   
U.S. Nuclear Regulatory  
U.S. Nuclear Regulatory  
Line 163: Line 99:
January 16, 2018 X-energy's  
January 16, 2018 X-energy's  
responses  
responses  
to RIS 2017-08 contains  
to RIS 2017-08 contains commercially  
commercially  
sensitive  
sensitive  
proprietary  
proprietary  
Line 170: Line 105:
and, as such, we are requesting  
and, as such, we are requesting  
that this information  
that this information  
be withheld  
be withheld from public disclosure  
from public disclosure  
in accordance  
in accordance  
with 10 CFR 2.390, "Public inspections,  
with 10 CFR 2.390, "Public inspections, exemptions, request for withholding," paragraph (a)(4). Since Commercially  
exemptions,  
request for withholding,"  
paragraph  
(a)(4). Since Commercially  
Proprietary  
Proprietary  
information  
information  
constitutes  
constitutes  
much of replies herein, a public version is not being submitted.  
much of replies herein, a public version is not being submitted.  
Accordingly,  
Accordingly, Enclosure  
Enclosure  
1 is the Non-Public  
1 is the Non-Public  
version of energy's  
version of energy's responses  
responses  
to RIS 2017-08 which contains non-redacted  
to RIS 2017-08 which contains  
non-redacted  
sensitive  
sensitive  
information.  
information.  
Line 196: Line 123:
marked and an affidavit  
marked and an affidavit  
providing  
providing  
the basis for this request is provided  
the basis for this request is provided in Enclosure  
in Enclosure  
2. Sincerely, President  
2. Sincerely,  
X Energy, LLC Cc: Amy Cubbage, NRC, TWFN (NRO/DSRA/ARPB)  
President  
James Hammelman, NRC, TWFN 4 A60 John Monninger, NRC TWFN 9 F41 John Segala, NRC, TWFN (NRO/DSRA/ARPB)  
X Energy, LLC Cc: Amy Cubbage,  
NRC, TWFN (NRO/DSRA/ARPB)  
James Hammelman,  
NRC, TWFN 4 A60 John Monninger,  
NRC TWFN 9 F41 John Segala, NRC, TWFN (NRO/DSRA/ARPB)  
Brian Smith, NRC, RGN-1 (R-I/DRP/PB4/BRO)  
Brian Smith, NRC, RGN-1 (R-I/DRP/PB4/BRO)  
Enclosures:  
Enclosures:  
1) Response  
1) Response to RIS 2017-08 2) Affidavit  
to RIS 2017-08 2) Affidavit  
Page 2 of 20   
Page 2 of 20   
X-energy  
X-energy Affidavit  
Affidavit  
Page 18 of 20 Enclosure  
Page 18 of 20 Enclosure  
2 to X-energy  
2 to X-energy Letter XE-X1-LD-GO-L03-100264   
Letter XE-X1-LD-GO-L03-100264   
X-energy Enclosure  
X-energy  
2 to X-energy Letter XE-X1-LD-GO-L03-100264  
Enclosure  
2 to X-energy  
Letter XE-X1-LD-GO-L03-100264  
I, Harlan W. Bowers, President  
I, Harlan W. Bowers, President  
of X-Energy,  
of X-Energy, LLC (X-energy)  
LLC (X-energy)  
do hereby affirm and state: 1. I am authorized  
do hereby affirm and state: 1. I am authorized  
to execute this affidavit  
to execute this affidavit  
Line 230: Line 146:
to or discussed  
to or discussed  
with the Nuclear Regulatory  
with the Nuclear Regulatory  
Commission  
Commission (NRC) and apply for the withholding  
(NRC) and apply for the withholding  
of information  
of information  
from disclosure.  
from disclosure.  
The purpose of this affida-vit  
The purpose of this affida-vit  
is to provide the information  
is to provide the information  
required  
required by 10 CFR 2.390(b) in support of X-energy's  
by 10 CFR 2.390(b)  
in support of X-energy's  
request for proprietary  
request for proprietary  
treatment  
treatment  
Line 246: Line 159:
in enclosure  
in enclosure  
1 to X-energy's  
1 to X-energy's  
letter, XE-X1-LD-GO-L03-100264,  
letter, XE-X1-LD-GO-L03-100264, from myself to the NRC which provides response to Regulatory  
from myself to the NRC which provides  
Issues Summary (RIS) 2017-08. 2. I have knowledge  
response  
of the criteria used by X-energy in designating  
to Regulatory  
Issues Summary (RIS) 2017-08.  
2. I have knowledge  
of the criteria  
used by X-energy  
in designating  
information  
information  
as sensitive,  
as sensitive, proprietary, or confidential.  
proprietary,  
3. Pursuant to the provision  
or confidential.  
of paragraph (a)(4) of 10 CFR 2.390, the following  
3. Pursuant  
to the provision  
of paragraph  
(a)(4) of 10 CFR 2.390, the following  
is furnished  
is furnished  
for consideration  
for consideration  
by the NRC in determining  
by the NRC in determining  
whether the information  
whether the information  
sought to be withheld  
sought to be withheld from public disclosure  
from public disclosure  
should be withheld.  
should be withheld.  
a. The information  
a. The information  
sought to be withheld  
sought to be withheld from public disclosure  
from public disclosure  
in Enclosure  
in Enclosure  
1 is owned by X-energy,  
1 is owned by X-energy, its affiliates  
its affiliates  
or third parties to whom X-energy has an obligation  
or third parties to whom X-energy  
to maintain its confidentiality.  
has an obligation  
to maintain  
its confidentiality.  
This information  
This information  
was prepared  
was prepared with the explicit understanding  
with the explicit  
understanding  
that the information  
that the information  
itself would be treated as proprietary  
itself would be treated as proprietary  
Line 299: Line 195:
1 is of the type that is customarily  
1 is of the type that is customarily  
held in confidence  
held in confidence  
by X-energy,  
by X-energy, and there is a rational basis for doing so. The information  
and there is a rational  
X-energy is requesting  
basis for doing so. The information  
to be withheld from public disclosure  
X-energy  
includes commercial  
is requesting  
to be withheld  
from public disclosure  
includes  
commercial  
information  
information  
related to on-going  
related to on-going and planned activities  
and planned activities  
associated  
associated  
with our Xe-100 high temperature  
with our Xe-100 high temperature  
gas pebble bed reactor design and the X-energy  
gas pebble bed reactor design and the X-energy TRISO-X fuel program. X-energy limits access to this privileged  
TRISO-X fuel program.  
X-energy  
limits access to this privileged  
information  
information  
to maintain  
to maintain confidentiality.  
confidentiality.  
d. Enclosure  
d. Enclosure  
1 contains  
1 contains information  
information  
about the planned activities  
about the planned activities  
of X-energy  
of X-energy related to the creation and submittal  
related to the creation  
and submittal  
of licensing  
of licensing  
activities,  
activities, forecast design development  
forecast  
timeframes, fuel fabrication  
design development  
facility deployment  
timeframes,  
fuel fabrication  
facility  
deployment  
plans, and commercial  
plans, and commercial  
strategy  
strategy of our Xe-100 advanced reactor. Public disclosure  
of our Xe-100 advanced  
reactor.  
Public disclosure  
of the information  
of the information  
contained  
contained  
in Enclosure  
in Enclosure  
1 would create substantial  
1 would create substantial  
harm to X-energy  
harm to X-energy because it would reveal valuable business information  
because it would reveal valuable  
business  
information  
regarding  
regarding  
X-energy's  
X-energy's  
competitive  
competitive  
expectations,  
expectations, assumptions, current position and strategy.  
assumptions,  
current position  
and strategy.  
Its use by a competitor  
Its use by a competitor  
could substantially  
could substantially  
improve their competitive  
improve their competitive  
position  
position in the design, manufacture, licensing, construction  
in the design, manufacture,  
licensing,  
construction  
and operation  
and operation  
of a similar product.  
of a similar product. Page 19 of 20   
Page 19 of 20   
X-energy Enclosure  
X-energy  
2 to X-energy Letter XE-X1-LD-GO-L03-100264  
Enclosure  
2 to X-energy  
Letter XE-X1-LD-GO-L03-100264  
e. The Proprietary  
e. The Proprietary  
Information  
Information  
Line 376: Line 240:
to the NRC in confidence  
to the NRC in confidence  
and under the provisions  
and under the provisions  
of 10 CFR 2.390; it is to be received  
of 10 CFR 2.390; it is to be received in confidence  
in confidence  
by the NRC. The information  
by the NRC. The information  
is properly  
is properly marked. I declare under the penalty of perjury that the foregoing  
marked. I declare under the penalty of perjury that the foregoing  
is true and correct. Executed on J af'M,UN~ [1 j 20 ( 8 [Month Day, Year] Harlan W. Bowers President  
is true and correct.  
Executed  
on J af'M,UN~  
[1 j 20 ( 8 [Month Day, Year] Harlan W. Bowers President  
X Energy, LLC Subscribed  
X Energy, LLC Subscribed  
and sworn to before me, Notary Public, this/?'"  
and sworn to before me, Notary Public, this/?'" day oifo "'"''jP My Commission  
day oifo "'"''jP My Commission  
expires: \' 11,l,'*1 1 1 , 1111 , ,,,\ ,. /' I;' ,..._.., __________  
expires:  
_, WANDA HOLBROOK Notary Public Anne Arundel County Maryland ' -~ \ ' ' .. ..:. , ... .. My Commission  
\' 11,l,'*111,1111, ,,,\ ,. /' I;' ,..._..,  
Expires: g-; d-~:. '. I Page 20 of 20
__________  
_, WANDA HOLBROOK  
Notary Public Anne Arundel County Maryland  
' -~ \ ' ' .. ..:. , ... .. My Commission  
Expires:  
g-; d-~:. '. I Page 20 of 20
}}
}}

Revision as of 04:30, 6 July 2018

X-Energy, LLC - Updated Design and Licensing Submittal Information NRC Regulatory Issue Summary (RIS) 2017-08 - Process for Scheduling and Allocating Resources for Fiscal Years 2020 Through 2022 for the Review of New Licensing Applications
ML18019A158
Person / Time
Site: PROJ0818
Issue date: 01/16/2018
From: Bowers H
X-Energy
To: Amy Cubbage
Document Control Desk, Office of New Reactors
References
RIS 2017-08, XE00-R-R1-RD-L-000027
Download: ML18019A158 (5)
v • d • e


See also: RIS 2017-08

Text

X-energy January 16, 2018 Ms. Amy Cubbage U.S. Nuclear Regulatory

Commission

ATIN: Document Control Desk Washington, D.C. 20555-0001

Subject: UPDATED DESIGN AND LICENSING

SUBMITIAL

INFORMATION

NRC REGULATORY

ISSUE SUMMARY (RIS)2017-08

PROCESS FOR SCHEDULING

AND ALLOCATING

RESOURCES

FOR FISCAL YEARS 2020 THROUGH 2022 FOR THE REVIEW OF NEW LICENSING

APPLICATIONS

FOR LIGHT-WATER

REACTORS AND NON-LIGHT-WATER

REACTORS X Energy, LLC 7701 Greenbelt

Road Suite 320 Greenbelt, MD 20770 +1301-358-5600

XEOO-R-Rl-RD-L-000027

The purpose of this letter is to submit responses

to Regulatory

Issue Summary (RIS) 2017-08 on behalf of X Energy, LLC (X-energy").

This submission

also updates the prior X-energy submitted

responses

to RIS 2015-07 (response

dated November 23, 2015) and RIS 2013-18 (response

dated March 28, 2014). X-energy is a private, wholly-owned

U.S. company that is pursuing the commercialization

of an advanced high temperature

gas-cooled

pebble bed reactor (HTGR), designated

as Xe-100 (X-energy

200 MWt), using U.S.-developed

uranium oxicarbide (UCO) TRISO-coated

particle fuel, in conjunction

with NRC approval.

X-energy's

design approach leverages

over 50 years of research, proven design, and operational

experience

in HTGR using a pebble bed architecture.

In addition to developing

the design of the Xe-100 pebble bed reactor, X-energy, through a US DOE cooperative

agreement, is actively fabricating

UCO based kernels, TRISO particles, and spherical

pebble fuel elements in a well-equipped, X-energy operated facility at the Oak Ridge National Laboratory (ORNL). In the future, this work in TRISO-based

fuel element production (referred

to as our "TRISO-X" program) will be spun off into a separate fuel fabrication

company that will ultimately

provide fuel for all UCO TRISO-based

reactor designs, which may include some Accident Tolerant Fuel (ATF) designs applicable

to the existing fleet of light water reactors.

The Xe-100 design and TRISO fuel manufacturing

are well aligned with, and leverage, the Department

of Energy's (DOE) Next Generation

Nuclear Plant (NGNP) and Advanced Gas Reactor (AGR) fuel qualification

initiatives, _with the fuel qualification

program established

as the number 1 priority by the Energy Policy Act of 2005 (EPACT2005).

In fact, the on-going TR ISO-based

fuel fabrication

activities

at ORNL take place in the laboratory

previously

used to produce AGR qualification

test articles.

The Xe-100 utilizes intrinsically

safe features with a simplified

plant design to assure enhanced safety and security.

Furthermore, the Xe-100 offers several inherent features reducing proliferation

risks and, with the potential

to utilize a future thorium-based

fuel cycle, has the capacity to recycle spent fuel and reduce current stockpiles

of plutonium

with the very high burn-ups inherent to the Thorium fuel cycle. X-energy has no affiliation, official or otherwise, with any other company working on the pebble bed approach to HTGRs. X-energy is U.S.-owned

and operates out of facilities

in Greenbelt, Maryland and Oak Ridge, Tennessee.

MD O:) y&ol {\) f_ 0

U.S. Nuclear Regulatory

Commission

January 16, 2018 X-energy's

responses

to RIS 2017-08 contains commercially

sensitive

proprietary

information

and, as such, we are requesting

that this information

be withheld from public disclosure

in accordance

with 10 CFR 2.390, "Public inspections, exemptions, request for withholding," paragraph (a)(4). Since Commercially

Proprietary

information

constitutes

much of replies herein, a public version is not being submitted.

Accordingly, Enclosure

1 is the Non-Public

version of energy's responses

to RIS 2017-08 which contains non-redacted

sensitive

information.

This proprietary

information

is appropriately

marked and an affidavit

providing

the basis for this request is provided in Enclosure

2. Sincerely, President

X Energy, LLC Cc: Amy Cubbage, NRC, TWFN (NRO/DSRA/ARPB)

James Hammelman, NRC, TWFN 4 A60 John Monninger, NRC TWFN 9 F41 John Segala, NRC, TWFN (NRO/DSRA/ARPB)

Brian Smith, NRC, RGN-1 (R-I/DRP/PB4/BRO)

Enclosures:

1) Response to RIS 2017-08 2) Affidavit

Page 2 of 20

X-energy Affidavit

Page 18 of 20 Enclosure

2 to X-energy Letter XE-X1-LD-GO-L03-100264

X-energy Enclosure

2 to X-energy Letter XE-X1-LD-GO-L03-100264

I, Harlan W. Bowers, President

of X-Energy, LLC (X-energy)

do hereby affirm and state: 1. I am authorized

to execute this affidavit

on behalf of X-energy.

I am further authorized

to review information

submitted

to or discussed

with the Nuclear Regulatory

Commission (NRC) and apply for the withholding

of information

from disclosure.

The purpose of this affida-vit

is to provide the information

required by 10 CFR 2.390(b) in support of X-energy's

request for proprietary

treatment

of certain commercial

information

submitted

in enclosure

1 to X-energy's

letter, XE-X1-LD-GO-L03-100264, from myself to the NRC which provides response to Regulatory

Issues Summary (RIS) 2017-08. 2. I have knowledge

of the criteria used by X-energy in designating

information

as sensitive, proprietary, or confidential.

3. Pursuant to the provision

of paragraph (a)(4) of 10 CFR 2.390, the following

is furnished

for consideration

by the NRC in determining

whether the information

sought to be withheld from public disclosure

should be withheld.

a. The information

sought to be withheld from public disclosure

in Enclosure

1 is owned by X-energy, its affiliates

or third parties to whom X-energy has an obligation

to maintain its confidentiality.

This information

was prepared with the explicit understanding

that the information

itself would be treated as proprietary

and confidential

and has been held in confidence

by X-energy.

b. The information

sought to be protected

in Enclosure

1 is not available

to the public to the best of my knowledge

and belief. c. The information

contained

in Enclosure

1 is of the type that is customarily

held in confidence

by X-energy, and there is a rational basis for doing so. The information

X-energy is requesting

to be withheld from public disclosure

includes commercial

information

related to on-going and planned activities

associated

with our Xe-100 high temperature

gas pebble bed reactor design and the X-energy TRISO-X fuel program. X-energy limits access to this privileged

information

to maintain confidentiality.

d. Enclosure

1 contains information

about the planned activities

of X-energy related to the creation and submittal

of licensing

activities, forecast design development

timeframes, fuel fabrication

facility deployment

plans, and commercial

strategy of our Xe-100 advanced reactor. Public disclosure

of the information

contained

in Enclosure

1 would create substantial

harm to X-energy because it would reveal valuable business information

regarding

X-energy's

competitive

expectations, assumptions, current position and strategy.

Its use by a competitor

could substantially

improve their competitive

position in the design, manufacture, licensing, construction

and operation

of a similar product. Page 19 of 20

X-energy Enclosure

2 to X-energy Letter XE-X1-LD-GO-L03-100264

e. The Proprietary

Information

contained

in Enclosure

1 is transmitted

to the NRC in confidence

and under the provisions

of 10 CFR 2.390; it is to be received in confidence

by the NRC. The information

is properly marked. I declare under the penalty of perjury that the foregoing

is true and correct. Executed on J af'M,UN~ [1 j 20 ( 8 [Month Day, Year] Harlan W. Bowers President

X Energy, LLC Subscribed

and sworn to before me, Notary Public, this/?'" day oifo "'"jP My Commission

expires: \' 11,l,'*1 1 1 , 1111 , ,,,\ ,. /' I;' ,..._.., __________

_, WANDA HOLBROOK Notary Public Anne Arundel County Maryland ' -~ \ ' ' .. ..:. , ... .. My Commission

Expires: g-; d-~:. '. I Page 20 of 20

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