Category Archives: Federal Regulation (U.S.)

Benicia Herald: Release date of Valero DEIR, background

Repost from The Benicia Herald
[Editor: Note in the concluding paragraphs: “Million said city staff and refinery employees have been in conversation as the review draft has been prepared….This is typical of any application…’We work with an applicant to get them on board.'”  This should not be news, nor surprising, but it underscores the impression among citizen-opponents of the project that our City is a willing partner with Valero.  It will be interesting to see what mitigations and conditions have been written into the DEIR so as not to stand as “deal breakers” for the “applicant.”  – RS]

Crude-by-Rail plan review to be released June 10

May 1, 2014 by Donna Beth Weilenman

The draft of the Environmental Impact Report (EIR) being prepared for the Valero Crude-by-Rail Project will be released by June 10, Principal Planner Amy Million announced Thursday.

The long-awaited document will be given a 45-day public review, during which people may submit their comments, she said.

That review period ends July 25.

“We have been notified that the City’s independent evaluation and Draft Environmental Impact Review (DEIR) of Valero’s Crude-by-Rail project will be available for public comment by June 10,” Chris Howe, Benicia Valero Refinery director of health, safety, environment and government affairs, said in an email Thursday.

Those interested will be able to read the draft EIR on the city’s website, www.ci.benicia.ca.us, by clicking on the Department of Community Development, Planning and Current Projects links under “City Departments.”

They also will be able to examine paper copies at the Community Development Department desk at City Hall and at Benicia Public Library, Million said.

Should a member of the public request it, she said, the city would make CD copies available as well.

The Planning Commission will accept public comment on the matter during a hearing at its July 12 meeting at City Hall, Million said. However, no vote will be cast that night, she said.

Once the comments are received, the city will prepare its response to those observations.

Those comments and any changes to the environmental review will be incorporated into the draft when the city produces the final version of the EIR. “There could be additional information,” Million said.

Should those comments and responses mean the draft needs to be “substantially modified,” the review would be rewritten and undergo a complete recirculation, she said.

Otherwise, if the comments and modifications aren’t considered substantial, the final version of the review would be sent to the Planning Commission for its review and vote as part of the refinery’s use permit request for its rail project.

The commission’s decision would be final, unless an appeal is filed, Million said. Should that happen, the City Council would hear the appeal and render a decision, she said.

The refinery applied for a use permit early in 2013 to extend Union Pacific Railroad’s tracks into Valero property so crude from North American sources can be brought into the plant.

Refinery officials in their application stated that the crude brought by train would not be in addition to the oil that arrives by tanker ships or pipelines, but would be substitutions. Up to 70,000 barrels would arrive daily by rail car, supplanting the same volume Valero currently receives by other methods.

Valero officials, declining to provide what they called proprietary information to competitors, have been reluctant to say where the crude is being drilled. Unlike some oil companies, Valero drills no wells of its own, but buys its crude.

Various company officials, speaking on multiple occasions, have stressed that the raw product would be similar to what it receives at its own local port.

Some opponents to the project, however, have warned that the rail cars would bring in Canadian tar sands, which is a heavier substance made “sour” by a larger percentage of sulfur. Others have suggested the source would be the North American Bakken oil fields, described as much lighter and sweeter.

Bakken crude also has a lower flash point than many oils, and has been associated with several explosions that have occurred after train car derailments.

The most recent accident happened Wednesday in downtown Lynchburg, Va., after breaches apparently developed on some of the crude-carrying rail cars on a CSX train.

A fireball shot 200 feet into the air, according to some observers. Oil was reported leaking into the James River.

Though no injuries were reported initially, at least 300 people were evacuated and neighboring cities were told to switch to alternate water sources, according to reports describing the incident.

It was the latest in a series of fiery accidents on crude-carrying trains, though none is reported to involve Union Pacific, a company that, along with the Valero refinery, continues to stress its safety record. North American rail delivery of crude has increased dramatically in the last couple of years. In the third quarter of 2013 alone, trains delivered 66 million barrels of crude, much from the Bakken fields of North Dakota.

That amounts to approximately 900 percent of what was delivered during all of 2008.

Last July, 47 people in Lac-Megantic, Quebec, Canada, died when an unmanned parked oil tanker train came loose, derailed and caught fire. People were evacuated in Edmonton, Alberta, last October after another derailment.

Thousands of barrels of oil contaminated an Alabama marshland after an oil train spill last November. A month later, two trains in Casselton, N.D., collided. One carried soybeans; the other, a BNSF train, spilled about 400,000 gallons of crude when 18 tank cars  ruptured and caught fire.

In February, BNSF announced it was seeking vendors to deliver up to 5,000 tanker cars that are stronger than those currently in use. That’s an unusual move for a large carrier, which usually requires clients to buy or lease rail cars. The railroad said it would use the reinforced cars not only for crude but also for carrying ethanol.

At a March public meeting organized by its community advisory panel, Valero officials said the refinery also would use the stronger cars to bring crude to Benicia.

Unlike the U.S. Department of Transportation, Transport Canada announced April 23 that it would remove Department of Transportation-111 unpressurized tank cars from what it called “dangerous service,” saying they didn’t meet standards for carrying dangerous fuel.

In the United States, railroads are federally regulated, a fact that has worried some residents when they learn that state, county and city officials are limited in the controls they can impose on that industry.

The U.S. National Transportation Safety Board has recommended that federal regulators upgrade requirements for oil-carrying cars, most of which are the DOT-111s.

The Association of American Railroads, freight carriers and Amtrak, has endorsed the upgrade. DOT officials have said they have met resistance to that change from those in the oil industry.

In the interim, the AAR and U.S. Transportation Secretary Anthony Foxx have announced a series of voluntary operating practices for crude-by-rail shipments that began last February. By April, rail lines promised increased track inspections and upgraded braking systems on trains with 20 or more carloads of crude oil.

Railroads said by July they would be using the Rail Corridor Risk Management System to determine which routes would be safer for trains with 20 or more crude-carrying cars, reduce those trains’ speeds and install more wheel-bearing detectors, among other measures.

Originally, Valero employees had hoped the Crude-by-Rail Project would be wrapped up within a year of filing the application in February 2013.

But once the project was announced, City Hall received heavy public input.

Opponents that included both residents and parties outside the city expressed concern about hazards associated with rail delivery of crude, the trains’ impact on traffic near Interstate 680 and inside Benicia Industrial Park, dangers to nearby environmentally sensitive wetlands, the threat posed to Benicia’s neighbors from explosions and spills, and the cumulative impact of rail delivery of crude to other Bay Area refineries.

Proponents said the project would create construction jobs while it was being built, add jobs to Valero once it was complete and equip the local refinery to compete with industry rivals.

The project has received support from Valero’s neighbors, including AMPORTS, which operates the Port of Benicia, and members of the board of the Benicia Chamber of Commerce.

Residents and others packed several city meetings on the project, including a July 11, 2013, Planning Commission meeting at which 31 people spoke.

During such hearings, every chair in the Council chamber has been filled; people lined walls and sat on the floor, waiting to speak or to hear what others said.

Speakers usually were split, with about half speaking passionately in favor of the project and the same number just as determined in their opposition.

The city initially issued a notice of intent to adopt a mitigated negative declaration for the project, which launched a 30-day comment period that ended July 1, 2013. During that time, the city received 34 written comments, some of which were substantial in length. After the closing date, 27 more written comments arrived; comments continue to be sent to City Hall.

The Benicia-based Good Neighbor Steering Committee organized a meeting last year at which a variety of speakers opposed to the project, including Diane Bailey, senior scientist for the Natural Resources Defense Council, described hazards associated with the import of tar sands crude from Canada.

Because of the volume of comments, the city notified the Office of Planning and Research, Sacramento, Aug. 9, 2013, that it would prepare an Environmental Impact Report, a much lengthier examination than the mitigated negative declaration, to comply with California Environmental Protection Act requirements.

Valero officials said they concurred with the decision.

“We consulted with city staff and agreed to work with them to prepare an Environmental Impact Report (EIR) for the Crude-by-Rail Project,” Sue Fisher Jones, Valero Benicia Refinery public affairs manager, said at the time.

Even after the city announced its intent to have the have the EIR written, proponents and opponents continued to have meetings about the project.

Bailey returned to Benicia last March for a meeting organized by the Steering Committee of Benicians for a Safe and Healthy Community. Joining her were Andres Soto, who has organized Communities for a Better Environment that opposes the increased delivery of crude by rail in the Bay Area; Damien Luzzo of Davis, who expressed worries about dangers to cities such rail cars would pass or go through; and, by video, Marilaine Savard, a resident of Lac-Megantic who described how the explosion devastated her home town.

At Valero’s own public meeting in March, speakers included refinery safety officers and environmental managers; Liisa Lawson Stark, director  Union Pacific public affairs; and Phillip Daum, an engineer who has participated in investigations of recent rail explosions, including the one at Lac-Megantic.

Valero Benicia Refinery officials won’t get to see the draft EIR any sooner than anyone else, Million said.

“We will receive the document at the same time it is available to the public,” Howe concurred. “We will have the same opportunity to provide comments as anyone else during the public comment period.”

He said his company anticipates arranging another public meeting once the draft EIR is released, and “the details for the meeting will be determined” then.

Million said city staff and refinery employes have been in conversation as the review draft has been prepared.

“They have been an integral part, because they have in-house expertise to answer technical questions,” she said. “They have a grasp of what the document says.”

This is typical of any application, she said, and Valero isn’t being treated differently from the way another individual or business that applies for a use permit or variance would be treated.

“We work with an applicant to get them on board,” she said of the way her department interacts with anyone filing an application.

Applicants also are given “a head’s up” about an environmental report’s developments, she said, adding that some applicants decide certain conditions are deal breakers.

The mitigations and conditions of approval for permits “are what the city feels is needed,” she said. “Ultimately, the comfort level is with the city.”

NY Times report on Lynchburg explosion and long-delayed federal safety rules

Repost from The New York Times

As New Shipping Rules Are Studied, Another Oil Train Derails

By CLIFFORD KRAUSS and TRIP GABRIEL  |  APRIL 30, 2014

A CSX oil train derailed on Wednesday in Lynchburg, Va.                         Credit: Luann Hunt/City of Lynchburg, via Associated Press

In the latest accident involving rail cars carrying crude oil, a CSX train derailed and erupted into black, smoky flames on Wednesday in downtown Lynchburg, Va., forcing scores of people to evacuate and causing a spill in the James River.

Hours later, the Transportation Department said that a long-awaited package of rules aimed at improving the safety of oil transport by rail had been sent Wednesday night to the White House for review.

The proposed regulations were not made public, but they follow Canada’s announcement of stiffer regulations last week and are expected to include measures requiring transport companies to replace old tank cars with more robust models that are resistant to puncture.

It was the second train accident involving crude oil for CSX this year.

As smoke billowed into the air, frightened shoppers, office workers and residents evacuated a 20-block area of Lynchburg, a city of 77,000. There were no reported injuries.

Images from the scene uploaded to social media and broadcast by local television showed mangled tracks along the river and three black tankers that slid down the bank into the water.

nyt-lynchburg-mapsThe Transportation Department said that the agency’s Federal Railroad Administration last inspected track in the area where the train derailed on Jan. 8 and did not find any violations or significant defects.

Leaking oil briefly ignited. An eyewitness told WSET-TV in Lynchburg that the flames leapt as high as the 19th floor of the office building where he watched the accident.

Within an hour of the derailment, the smoke and flames had largely subsided. City officials said 13 to 14 cars derailed and three to four cars had ruptured. They were unsure how much oil drained into the river.

The city of Richmond, about 120 miles downstream, was preparing to switch to an alternative water supply in case oil reached it, The Richmond Times-Dispatch reported. The Lynchburg water supply’s intake is upstream of the wreck.

“An initial assessment indicates that three of the cars were on fire,” CSX said in a brief statement. The company did not say what caused the accident.

The train was traveling from Chicago to Virginia when the derailment occurred at 2:30 p.m.

The company said it sent emergency personnel, environmental workers and community support teams. Federal rail inspectors were also at the scene of the derailment.

Train traffic carrying crude was relatively rare until four years ago, when oil companies in North Dakota began shipping large quantities of Bakken shale crude out of the state by rail because there was insufficient pipeline capacity to do the job.

Some cars of the CSX train that derailed Wednesday in Lynchburg, Va., fell into the James River.  Credit: WSET/Reuters       

Now, much of the production of the Bakken region is sent by rail on trains that can stretch up to a mile long and carry roughly 85,000 barrels of oil.

When a runaway train carrying Bakken crude derailed and exploded last July in the Quebec town of Lac-Mégantic, killing 47 people, the safety issues surrounding the transportation of crude through populated areas rose in importance for both American and Canadian regulators.

Then, in December, an oil train passing through Casselton, N.D., derailed and exploded, sending flames high into the air and forcing some residents to evacuate. That followed an accident in November, when another oil train derailed in Alabama, spilling crude oil.

Many of the trains are destined for refineries on the East Coast, which have a strong desire to replace expensive imported crude from the Middle East and Africa with the high-quality, and less expensive, crude from North Dakota.

In response to the rising concerns, federal regulators and railroads agreed in February to a series of voluntary measures to improve safety, including lower speed limits for oil trains in urban areas, increasing the frequency of track inspections and adding more brakes on trains.

And last week, Canada issued tough new rules requiring emergency plans from railroads on responding to catastrophic accidents and requiring companies to retire older models of tank cars within three years. The new model of tank car, developed in 2011, would effectively set a new standard of safety for rail companies in the United States since many lines cross the United States-Canadian border.

But despite years of discussion, American regulators have lagged on requiring stronger tank cars, which are generally owned by oil companies and private investors, not by railroad companies.

Safety experts have warned for more than 20 years that the older tank cars, called DOT-111s, are prone to rupture in a derailment.

Environmentalists quickly made the case on Wednesday that the accident was another sign of the dangers of oil drilling, even though they are also critical of alternative pipeline transport.

“The accident is a potent reminder of the dangers that come with our dependence on dirty fuels,” the Sierra Club said in a statement, “and the need for better safety measures and increased emergency preparedness.”

NY Governor Cuomo sends letter to President Obama an hour before Lynchburg explosion

Repost from The Auburn Citizen, Auburn, NY
[Editor: See below for copy of Governor Cuomo’s letter and the New York State Transporting Crude Oil Report.  – RS]

Cuomo to President Obama: Better federal safety standards needed for rail transport of crude oil

April 30, 2014 • Robert Harding
Train Derailment
Firefighters and rescue workers work along the tracks where several CSX tanker cars carrying crude oil derailed and caught fire along the James River near downtown in Lynchburg, Va.., Wednesday, April 30, 2014. Police said that 13 or 14 tanker cars were involved in the derailment. (AP Photo/Steve Helber)

Shortly before a train carrying tankers filled with crude oil derailed and exploded in Lynchburg, Va., Gov. Andrew Cuomo urged the federal government to establish better safety regulations for the rail transport of crude oil to help prevent major accidents from occurring that could pose a threat to New York communities located along rail lines.

Cuomo sent a letter Wednesday to President Barack Obama calling for tougher federal regulations. In the letter, Cuomo included recommendations for the federal government, including new tank car regulations and updated environmental and contingency response plans. He also called for the removal of DOT-111 tank cars, a type of car that has been labeled “dangerous” because of the high risk of explosion if it derails carrying crude oil.

“As a result of the recent boom in domestic petroleum production, New York state is experiencing a dramatic increase in the number of crude oil trains passing through the state from production areas in the upper Midwest to refineries in the mid-Atlantic and Canada,” Cuomo wrote to President Obama. “This type of crude oil, known as Bakken crude, is highly volatile and is being transported in significant volume across the country by inadequate rail tank cars.

“New York and all the states subject to this crude oil boom are extremely vulnerable to the impacts of a derailment, spill, fire or explosion, as demonstrated by three catastrophic incidents in the last nine months involving such trains. I urge your immediate attention to this issue.”

The recommendations for the federal government were included in a report released Wednesday. The report, Transporting Crude Oil in New York State: A Review of Incident Prevention and Response Capacity, was prepared by a handful of state agencies after Cuomo issued an executive order in January.

While the report makes recommendations to the federal government for improving rail transportation safety, emergency preparedness and strengthening environmental protections, the agencies also recommended the state take action in these three areas.

The report also recommends industry changes, including implementation of a web-based information access system by rail companies to provide real-time information on hazardous materials. The agencies also called for an expedited risk analysis for crude oil to determine the safest and most secure rail routes for trains with at least 20 cars of crude oil.

While Cuomo said the state can take steps to be better prepared, he said it’s the federal government’s responsibility to regulate the industry.

“New York will continue to aggressively pursue measures that ensure its safety,” Cuomo wrote. “However, the fundamental responsibility for the safe transportation of crude oil across the country resides with federal agencies.”

Cuomo’s office distributed the governor’s letter to President Obama and the state report about an hour before reports of the train accident in Lynchburg, Va. The News & Advance in Lynchburg reports that an estimated 50,000 gallons of crude oil was spilled in the incident.

After learning of the train derailment, Cuomo issued a statement repeating his call for the federal government to take action.

“Earlier today, I wrote a letter to President Obama urging the federal government take immediate steps to bring much needed and overdue safety regulations to the crude oil transportation system. Just hours later, news comes of yet another serious oil train derailment, this time in Lynchburg, Virginia. Our thoughts and prayers are with any possible victims of this accident,” Cuomo said.

“This is the latest in a series of accidents involving trains transporting crude oil, a startling pattern that underscores the need for action. In addition to steps that states like New York are taking, the federal government must overhaul the safety regulations, starting with taking DOT-111 trains off the rails now. These trains travel through populated communities in upstate New York and we cannot wait for a tragic disaster in our state to act.”

Here is the letter from Cuomo to President Obama:

Gov. Cuomo’s letter to President Obama

Here is the state report on transporting crude oil:

New York State Transporting Crude Oil Report

NRDC Senior Scientist: Another explosion, and slow progress on tank car regulations

Repost from NRDC Switchboard, Diane Bailey’s Blog

This Washington, that Washington on Crude Oil by Rail

 Diane Bailey | Posted April 30, 2014

Diane Bailey

This afternoon brought news of another fiery crude oil train derailment.  Luckily no one was hurt in the Lynchburg, Virginia accident, but flames were shooting up as high as the 19th floor of one bystander’s office building, oil was spilling into the James River and hundreds have been evacuated.  The billowing black plumes of smoke serve as a warning not just to the 77,000 people living in Lynchburg but to everyone living near rail lines or terminals that the growing transport of long crude oil trains is incredibly dangerous.

It’s not clear that mile long crude oil trains can ever be made safe, but they are upon us, so while we are fighting to keep them out of communities, we better make every effort to improve the situation.  This blog includes notes on the National Transportation Safety Board Rail Safety Forum on the Transportation of Crude Oil and Ethanol  in Washington D.C. last week from Fred Millar, a well-known rail safety expert; and a summary of fieldwork from a leading activist, Matt Landon, who is oil trainspotting in Washington State. (What is oil trainspotting?)

The NTSB Forum in DC last week was packed with industry shippers and carriers, NTSB oil forum.jpgtechnical, policy, emergency response and regulatory experts, all talking about hazardous materials transportation issues and crude oil train derailments disasters. From that discussion, the top two strategies to address these safety risks involve federal regulations: (1) Ordering a fast retrofit of existing tank cars with a strong safety standard, and a similarly strong standard for new tank cars; and (2) re-routing the unit trains around major cities.

As far as the tank cars go, NTSB Chairman Hersman noted that federal agencies could use emergency powers to quickly issue safety-forcing Emergency Orders and even Interim Final Regulations.  She recounted an expeditious federal action in the 1970’s, when the DOT ordered speedy retrofits of pressurized “jumbo” tank cars DOT-112A and DOT-114A that experienced dangerous failures.

In February 1978, a rail tanker explosion killed 16, in Waverly, TN.  Less than a year later, in January 1979 the DOT Secretary reported that nearly all of the defective tanker cars had been retrofitted, and soon thereafter it was obvious that the package of three railcar retrofit devices had reduced serious pressurized railcar releases significantly. During that rulemaking process, it’s important to note that although the industry warned that only four shops could do railcar retrofits and they would take 3 days each, the NTSB ultimately found that 100 shops could retrofit tank cars, and each would take 93 minutes.

So, technically and politically, rail tanker cars can be retrofitted or replaced quickly. And in the case of the puncture-prone DOT-111 tanker cars now used to carry significant amounts of crude oil, speed is called for in their replacement as well.  According to researcher, Dr. David Jeong of DOT, using sophisticated models, the “legacy” DOT-111 tank cars are estimated to spill their contents in an accident over 25 percent of the time, whereas other models are less likely to breach in an accident. For example, COC-1232 tanker cars with full height head shields are estimated to breach in only 6 percent of accidents; and the proposed new design for more robust tanker cars with a thicker shell would only breach in 4 percent of accidents. While imperfect, these newer designs are clearly much safer and should be phased in immediately.

It remains to be seen what this week’s expected federal proposal on rail car safety will bring.  In the meantime, the Canadian government announced last week that industry must – at its own cost – replace 5,000 DOT-111 tanker cars within 30 days, and another 65,000 DOT-111 cars must be removed or retrofitted within three years.

This is a significant step, although three years is a long time to wait, and the regulations do not address re-routing of trains around cities.  In Canada, however, the railroads will have to provide hazmat rail flow information to local emergency responders (note: the public still will not have access to this). The US has no such requirement on the railroads.  Also, to make matters worse, the current “routing selection tools” used by railroads in the U.S. are not disclosed to anyone and receive minimal government oversight.  Railroads and governments have blocked any effort to keep dangerous trains away from the most populated areas by keeping the routing secret and unaccountable, unmeasured as to effectiveness.

firefighter tanker train.jpgHow can emergency responders deal with crude oil rail accidents?  A panel concluded that the best tactic is to let a derailment burn, pull back, and take a “defensive posture”.  Emergency responders were clear that the ongoing crude oil rail disasters are beyond their capabilities to handle.  “Even with an infinite amount of costly foam”, letting them burn is the only sensible approach (and this is what was done in Lynchburg this afternoon).  They note that major derailments would require enormous amounts of foam, there is not enough water to apply it especially in rural areas, and anyway, they cannot get close enough to the fires to apply it.  Derailments in urban areas would pose significant operating risks that go well beyond current operational capabilities for emergency responders.

In the meantime, Matt Landon with the Vancouver Action Network, set out to find whether crude oil trains are leaking fumes in the other Washington – State, that is. This past month, Matt initiated the Washington State Train Watch 2014 covering Spokane, the Columbia River Gorge, Washougal, Camas, Vancouver, Fruit Valley, and Everett, recording the number of oil and coal trains coming through these communities.  Using a FLIR Gasfindir GF320 hydrocarbon viewing video camera, this footage of air emissions from a train carrying crude oil thought to be from the North Dakota Bakken was posted.  Watching this video makes you wonder who is monitoring the air emissions from leaky crude oil trains, how much is leaking, who is exposed and how dangerous is it?

leaking oil train.jpg

Back in Washington D.C., waiting for an announcement on new rail safety measures from U.S. DOT, Fred Millar provided more information from the rail safety forum.  Participants in the NTSB Forum recognize the scope and seriousness of the Crude by Rail issues, given that 80 percent of the 1 million barrels per day of Bakken crude oil produced is shipped by rail, and production is growing, yet there is no single silver bullet to address the rail safety risks.

In addition to the need for improved tanker cars and routing discussed above, there are additional improvements that can be made to rail operations and to emergency response.

One key factor in train derailments that influences the extent of damage is speed.  The models that predict failure rates of tank cars during derailments use an “average accident” speed of 27 mph. Yet, even the NTSB Chair Hersman pointed out that it is not realistic, given the higher speeds seen in some of the serious derailments in recent years and the fact that the new standard adopted by the railroads on routes outside of major cities is 50 mph.  Reducing train speeds would be one effective strategy to reduce risk of catastrophic derailments.

It is also essential to strengthen emergency response capabilities. No one at the Forum asked or speculated on what would it cost if railroads paid for adequate emergency preparedness or if FRA increased their oversight in any serious way. The scale of the needs here is vast, given that there are an estimated 2 million firefighters, 80% of which are volunteers, and 20% of those turn over every year.  They all need hazmat training and appropriate resources to respond in any real way to a unit crude oil train accident.rail placard.jpg

Finally, in order for emergency responders to do their jobs, they need to know what substance they are dealing with during an accident.  Full disclosure of tanker train contents and characteristics is essential.  Communities also have a right to know this information about the mile long trains hurtling through their neighborhood, but this was never even mentioned during the Forum.

The residents of Lynchburg, Virginia and thousands of others who have witnessed the devastation of crude oil train derailments over the past year probably join me in wondering whether the federal government is going to do anything to keep these dangerous oil trains out of communities, or try to make those tanker trains safer, or make the trains slow down, or provide adequate emergency response resources, or… anything.  How many more fiery derailments will it take to act?

Full notes of Fred Millar are available to community, public health and safety advocates upon request.