API wants EPA to keep Open Top Flowback Tanks in Urban Drilling

What does flowback look like? Heres the video link of these pics….

Screen shot 2014-12-10 at 10.51.07 AM Screen shot 2014-12-10 at 10.51.17 AM Screen shot 2014-12-10 at 10.51.28 AM Screen shot 2014-12-10 at 10.52.06 AM Screen shot 2014-12-10 at 10.52.19 AM Screen shot 2014-12-10 at 10.52.28 AM

8/29/14 UPDATE OSHA/NIOSH/CDC  study shows Benzene during flowback  exposes workers in higher amounts for those checking gauges on the tanks….what about us fence line people? We need a mask too.


In a recent NCTCOG Ozone Attainment work session, I asked the EPA to address a flowback emission stage called Top Flow Flowback in their New Source Performance Standards rules (NSPS).
The EPA is clarifying some of its NSPS language so please comment asap using the email address, “A-and-R-Docket@epa.gov” and reference in your attention line
… “Docket ID Number EPA– HQ–OAR–2010–0505”.   THANK YOU!
 In the “inital flowback stage” the mix of frac water, frac chemicals, NORM, heavy metals & BTEX is directed into OPEN HATCH flowback tanks near highly dense populated areas in the Barnett Shale. Best Available Control Technologies exist for closed, ventless, pressurized flowback tanks. Please clarify in your NSPS language to mandate Green Completions equipment that covers ALL stages of flowback,  thank you.

sample letter using the email address, “A-and-R-Docket@epa.gov” and reference in your attention line “Docket ID Number EPA– HQ–OAR–2010–0505”. Dear EPA, in the “inital flowback stage” the mix of frac water, frac chemicals, NORM, heavy metals & BTEX is directed into OPEN HATCH flowback tanks near highly dense populated areas in the Barnett Shale. Best Available Control Technologies exist for closed, ventless, pressurized flowback tanks. Please clarify in your NSPS language to mandate Green Completions equipment that covers ALL stages of flowback, thank you.

Below is the NCTCOG/TCEQ/EPA follow up as a string of communications on this subject that I boldfaced items for emphasis…
—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: A-and-R-Docket@epa.gov
Sent: Wednesday, July 23, 2014 3:11 PM
Subject: Re: Docket ID Number EPA– HQ–OAR–2010–0505
Regarding inital flowback handling/equipment being clarified on the NSPS rules (being now open for public comment), yesterday I submitted a public comment on this docket regarding how (sadly) the UT study was ONLY focused on Methane and not other HAP pollutants. Below I forwarded you an email verifying this.Several years ago, there were citizen & city funded air tests done during flowback from Colleyville TX.  In speaking with state toxicologist, Shannon Ethridge, about the (two week) air testing done in Colleyville, she told me that since the state’s Air Monitoring Comparison Values is a longterm annual exposure average, she could not compare them to the state AMCV values. Instead she gave me the Agency for Toxic Substances and Disease Registry’s acute 14 day Mimimal Risk Level of 9 ppb Benzene . Since the highest recording during flowback in Colleyville for Benzene was 85 parts per billion, that represents an exceedance over 9 times the ATSDR standard.
The Colleyvile, city hired, Modern Geosciences air testing representative wrote on 2/22/2012 .http://www.colleyville.com/images/content/files/communitydevelopment/final_air_quality_analysis_summary.pdf  “…it is recommended…to allow for incorporation of improved capture…..this may utilize vapor recovery units, a line separator to remove gases prior to the frac tank for collection in a pressurized vessel…”
Your own EPA has commented…
1. EPA: unacceptable VOC emissions from drilling flowback
“The additional air pollution emissions from hydraulic fracturing have been the subject of some recent study. The EPA estimates that uncontrolled hydraulically fractured wells may emit 240 times the amount of hazardous air pollutants as an unfractured well.*13 The concern is that once the well has been hydraulically fractured, the large amount of fluid returns up the bore hole to the surface where it is vented – releasing large amounts of hydrocarbons and chemicals used in the hydraulic fracturing process into the air. These flow-back emissions are short term in nature but are substantial.”
*13 U.S. Environmental Protection Agency. 2011. Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution, Office of Air and Radiation, July 2011 at 4-7. Available
at: http://www.epa.gov/airquality/oilandgas/pdfs/20110728tsd.pdf (hereinafter Standards of Performance)
Also the Garfield CO study also stated that flowback emissions seem to be the greatest stage of emissions for HAPS…
Thank you for allowing me to follow up comment with more information to help you in your decision to clarify the new EPA NSPS green completion rules to have a mandate for CLOSED HATCH flowback tanks to protect us and our environment.Kim Feil— On Wed, 7/23/14, Stanzione, Maria R <maria.stanzione@mail.utexas.edu> wrote:> From: Stanzione, Maria R <maria.stanzione@mail.utexas.edu>
> Subject: Methane Study Technical Inquiry
> To: “kimfeil@sbcglobal.net” <kimfeil@sbcglobal.net>
> Date: Wednesday, July 23, 2014, 9:20 AM> Hello Kim Feil,
>
> Thank you for your
> interest in the Methane Study conducted by The University of
> Texas at Austin.
>
> You submitted the
> question:
>
> When testing initial
> stages of flowback for gases/Methane, were any other
> pollutants such as frac chemicals, BTEX, NORM, or Heavy
> Metals tested for? Closed, ventless storage tanks make sense
> in an Urban area.
>
> The answer is no, we did
> not test for any other pollutants.  We only quantified
> methane in the gas sampling.
>   
>
> Thank you,> Maria
> Stanzione,
> M.Ed.
>
> Project Manager
>
> Center for Energy and Environmental Resources
>
> University of Texas at Austin
>
> (512) 232-5040
> maria.stanzione@austin.utexas.edu

—– Forwarded Message —–
From: kim feil <kimfeil@sbcglobal.net>
To: “A-and-R-Docket@epa.gov” <A-and-R-Docket@epa.gov>
Sent: Wednesday, July 23, 2014 12:59 AM
Subject: Docket ID Number EPA– HQ–OAR–2010–0505

In the “inital flowback stage”, the mix of frac water, frac chemicals, NORM, heavy metals & BTEX matter comes back up and goes into OPEN HATCH flowback tanks near highly dense populated areas in the Barnett Shale.
 
The flowback fluid has hydrocarbons and is under pressure…a white fog is seen wafting into our neighborhoods and the odors have been described as a burnt sewery smell…heart palpitations have been reported upon breathing it by Arlington residents.  Some other workers have actually died from it.
 
Companies like Vapor Point  I believe, sell a ventless, pressurized flowback tank and is an example of a Best Available Emission Control Technology, but most Barnett Shale city gas well ordinances have language for the operators to only use “industry standard” or “reasonable” control technologies…(not BE$T control technologies).
 
Thank you for your comment opportunity to improve or clarify the NSPS rules and identify myself as a stakeholder in living close to a drill site near the Cowboys Stadium in Arlington. I officially express the need for “Urban closed, ventless, flowback tanks”. 
 
*Below is your EPA Executive Summary items relevant to my request. 
 
Regarding Footnote 3 …“Recent studies have shown that air emissions from open top tanks used during initial flowback are very low. Allen, David, T., et al.2013.”  
It is that statement of low emissions during initial flowback that is misleading and incomplete as this study focused on measuring Methane. It does not include BTEX, NORM, heavy metals and frack chemicals associated with flowback.
Please be aware of recent information uncovered that COLLOIDS are leaching heavy metals out of the soil where frac spills or mudfarming has occurred at an alarming rate. This means runoff  more concentrated pollution is the equivalent of frack on crack.
 
The sheer build out of all the drilling/spills/land farming compounded with COLLOIDS makes for hazardous environmental contamination.
Please mandate closed, ventless, flowback tanks for all flowback stages in Urban areas, because our state and local governments will not do this and so it is left up to the operator or the EPA to make sure this protection is in place, thank you.
Sincerely
Kim Feil
*V. Executive Summary
The purpose of this action is to
propose amendments to 40 CFR part 60, 
subpart OOOO, Standards of 
Performance for Crude Oil and Natural 
Gas Production, Transmission and
Distribution. This proposal was
developed to address certain issues
primarily related to well completion
and storage vessel provisions that have
been raised by different stakeholders
through several administrative petitions
for reconsideration of the 2012 NSPS
and the 2013 storage vessel amendments
to the NSPS. The EPA is proposing to
amend the NSPS to address these issues.
We are proposing to amend the
standards for gas well affected facilities
to provide greater clarity concerning
what owners and operators must do
during well completion operations,
especially the provisions for reduced
emissions completions which have a
compliance date of January 1, 2015.
While the 2012 NSPS focused mainly on 
handling of flowback emissions, we did 
not provide extensive detail concerning 
requirements for handling of liquids 
during the well completion operation. 
In this action, we are proposing to 
identify three distinct stages of a well 
completion operation and specific 
requirements for handling of gases and 
liquids for each stage. The ‘‘initial 
flowback stage’’ begins with the onset of 
flowback following hydraulic fracturing 
or refracturing and ends when there is 
sufficient gas present in the flowback for 
a separator to operate. At that time, the
operator must direct the flowback to the
separator, and the ‘‘separation flowback
stage’’ begins. It is at this stage where
recovery of the gas begins, unless the
gas is unsuitable for entering the flow
line, or infrastructure to convey the gas
to market is not available, in which case
the gas is required to be combusted
unless combustion poses a safety
hazard. Once the flowback volume has
subsided and stabilized such that the
well is producing gas continuously to
the flow line or is shut in, and any crude
oil, condensate and produced water in
the flowback can be separated, the
‘‘production stage’’ begins and
continues as ongoing production of the
well. At that time, the separated and
recovered crude oil, condensate and
produced water must be routed to
storage vessels. At the beginning of the
production stage, the operator must
begin the 30-day process of estimating
storage vessel volatile organic
compound (VOC) potential to emit
(PTE) and must control emissions no
later than 60 days after the beginning of
the production stage. Beginning with
the production stage, the rule prohibits
venting or flaring of gas.
We are re-proposing for comment the
definition of ‘‘low pressure gas well,’’ as
related to the well completion
provisions. We added this definition in
the 2012 NSPS in response to public
comments. Petitioners asserted that the
definition is unnecessarily complicated
and would pose difficulty for smaller
operators. The petitioners provided a
very straightforward alternative on
which we are also soliciting comment.
We are proposing several
amendments related to the storage
vessel provisions of the NSPS. First, we
are proposing to amend the provisions
for determining PTE for storage vessels
with vapor recovery to clarify that the
provisions allowing sources to exclude
emissions captured through vapor
recovery if certain specified control
requirements are met do not apply to
storage vessels whose PTE is limited to
below the 6 tons per year (tpy)
applicability threshold under a legally
and practically enforceable permit or
other limitation under federal, state or
tribal authority. We are also proposing
to amend the storage vessel closed cover
requirements to allow other
mechanisms besides weighted lid thief
hatches to ensure that the thief hatch lid
remains properly seated. In addition, we
are proposing to amend slightly the
requirements for storage vessels to
clarify notification and other
requirements under the NSPS for
storage vessels that are removed from
service.
We are proposing to amend the
requirements for reciprocating
compressors to add a third alternative to
the two existing work practice options
for controlling emissions from rod
packing venting. We are proposing a
third alternative that would be to route
emissions from the rod packing through
a closed vent system to a process.
We are proposing two amendments to
the equipment leaks requirements for
natural gas processing plants. One is to
correct an inadvertent omission we
made in the 2012 NSPS concerning an
exemption from routine leak detection
in small gas processing plants and gas
processing plants located on the
Alaskan North Slope. In the 2012 NSPS,
we inadvertently failed to include
connectors in the list of equipment
under this exemption. In addition, we
are proposing to amend the definition of
‘‘equipment’’ to clarify that the term, as
used in relation to the equipment leaks
requirements under the NSPS, refers
only to equipment at onshore natural
gas processing plants.
We are proposing to amend the
definition of ‘‘responsible official’’ that
is used in conjunction with the
compliance certification provisions of
the 2012 NSPS. We are proposing to
amend the definition of ‘‘responsible
official’’ to provide for delegation of
authority after advance notification
rather than after approval, which is
currently required for delegation to
authorities responsible for facilities that
employ 250 or fewer employees and
have less than $25 million gross annual
sales or expenditures (in second quarter
1980 dollars). Requirements for
delegation to representatives
responsible for one or more facilities
that employ more than 250 persons or
have gross annual sales or expenditures
exceeding $25 million (in second
quarter 1980 dollars) are unchanged
from the 2012 NSPS (i.e., there is no
advance notification or approval
required for such delegations).
Finally, we are proposing to remove
the ‘‘affirmative defense’’ provisions
from the startup, shutdown and
malfunction provisions of the 2012
NSPS. We are also proposing to correct
technical errors in the 2012 NSPS.
Details and rationale for all the above
proposed amendments are presented in
section VI below.
VI. Discussion of Provisions Subject to
Reconsideration
As summarized above, the EPA is
proposing to address a number of issues
that have been raised by different
stakeholders through several
administrative petitions for
reconsideration of the 2012 NSPS final
action and 2013 storage vessel
amendments. The following sections
discuss the issues that the EPA is
addressing in this action and how the
EPA proposes to resolve the issues.
A. Well Completions 
Several petitioners raised issues with 
regard to the well completion provisions 
in the 2012 NSPS, including handling of 
flowback gases and liquids and
definition of ‘‘low pressure well.’’ While
the 2012 NSPS focused mainly on
handling of flowback gases, we did not
provide extensive detail concerning
requirements for handling of liquids
during the various stages of well
completion. The proposed amendments
to the regulatory text discussed below
provide clarity concerning what owners
and operators must do during
completion operations, and the
proposed amendments to the
requirements would maintain the same
level of reduction as the 2012 NSPS.
1. Handling of Flowback Gases and 
Liquids 
The petitioners asserted that the rule 
is unclear with regard to requirements
in § 60.5375 for handling of gases and
liquids during flowback and that, as
written, compliance with the existing
language cannot be achieved.
When Specifically, petitioners asserted that 
§ 60.5375(a)(1) which states ‘‘(F)or the 
duration of flowback, route the 
recovered liquids into one or more 
storage vessels . . . and route the 
recovered gas into a gas flow line or 
collection system . . . with no direct 
release to the atmosphere’’ could be 
interpreted to prohibit venting of gases 
at any time during the flowback period. 
According to petitioners, at the 
beginning of the flowback period, the 
flowback consists initially of water, 
fracturing fluids and proppant (sand) 
with no gas present. At some point, 
sporadic slugs of gas begin to appear in 
the flowback in increasing amounts 
until enough gas is present to approach 
flammability and to enable a separator 
to function. Petitioners explained that 
operators usually locate a monitor on 
the vessel receiving the initial flowback 
to sense the gas concentration. When
the gas concentration approaches
flammability, the flowback is then
directed to a separator. For a separator
to function, enough gas must be flowing
to maintain a gaseous phase and one or
more liquid phases within the separator.
In addition, petitioners explained that 
the requirement to ‘‘route the recovered 
liquids into one or more storage vessels’’ 
is not feasible because of the 
composition and high volumetric flow 
of the initial flowback that necessitate 
using open top tanks or a pit for this 
purpose. As explained by the 
petitioners, this initial high volume 
liquid flowback carries with it sand and 
debris that can be removed relatively 
easily from open top tanks or that can 
settle to the bottom of lined pits. The 
petitioners also explained that removal 
of sand and debris from a closed top 
tank is extremely difficult and must be 
performed manually. Petitioners further 
noted that, because temporary tanks are 
excluded from the definition of ‘‘storage 
vessel,’’ such temporary tanks as 
fracture tanks (frac tanks) cannot be 
used to comply with requirements of the 
2012 NSPS. 
In the EPA’s clarification letter to the 
American Petroleum Institute (API),1 2
we explained that it was not the EPA’s 
intent to prohibit venting of flowback 
gases throughout the entire flowback 
period and that we understood that 
there were periods during which gas 
may be present in the flowback but with 
insufficient volume and consistency of 
flow to enable either combustion or 
recovery of the gas through separation. 
Our clarification letter further 
responded to the issue of routing of all 
recovered liquids to storage vessels. We 
explained that the term ‘‘recovered 
liquids’’ refers to condensate, crude oil 
and produced water recovered through 
the separation process. Although the 
2012 NSPS does not define ‘‘recovered 
liquids,’’ the discussion of the proposed 
NSPS for storage vessels describes the 
storage of ‘‘crude oil, condensate and 
produced water.’’ (see 76 FR 72763, 
August 23, 2011). In our clarification 
letter to API, we stated that the 2012 
final rule accurately reflected our intent 
to require these liquids to be routed to 
‘‘storage vessels,’’ which may be subject 
to control in the rule depending on their 
potential to emit VOC and their affected 
facility status. We confirmed that the 
initial flowback (prior to recovery of 
these liquids through separation) may 
be routed to temporary fracture tanks 
(frac tanks) or other portable tanks (i.e., 
tanks that do not meet the definition of 
‘‘storage vessel’’) as long as separation 
occurs as soon as practicable, consistent 
with the general duty to maximize 
resource recovery and minimize releases 
to the atmosphere as required in 
§ 60.5375(a)(4). 
In light of petitioners’ assertions and 
the confusion caused by the current 
regulatory language in the well 
completion provisions, we reexamined 
the regulatory text in § 60.5375 and 
concluded that more clarity is needed 
such that owners, operators, regulatory
agencies and the public could readily
understand what was required at
various stages of a hydraulically
fractured well completion operation.
We believe that the requirements of
the rule would be easier to understand
if the rule identified distinct stages
associated with well completion, with
each stage having specific requirements
for handling of gases and liquids. To
that end, we are proposing that each
well completion subject to § 60.5375
consists of three distinct stages.
The first stage begins with the first 
flowback from the well following 
hydraulic fracturing or refracturing, and 
is characterized by high volumetric flow 
water, with sand, fracturing fluids and 
debris from the formation with very 
little gas being brought to the surface, 
usually in multiphase slug flow. As the
flowback proceeds, the amount of gas
appearing in the flowback increases to
the point where there is enough gas
present for a separator to function, at
which time the well completion would
enter the second stage. We are 
proposing that the first stage be defined 
as the ‘‘initial flowback stage,’’ during 
which the flowback must be routed to 
a ‘‘well completion vessel’’ that can be 
an open top frac tank, a lined pit or any 
other vessel. During the initial flowback 
stage, there would be no requirement for 
controlling emissions from the tank, and 
any gas in the flowback during this stage 
could be vented.3
 
 
Footnote 3 Recent studies have shown that air emissions 
from open top tanks used during initial flowback 
are very low. Allen, David, T., et al. 2013. 
Measurements of methane emissions at natural gas 
production sites in the United States. Proceedings 
of the National Academy of Sciences (PNAS) 500 
Fifth Street NW., NAS 340 Washington, DC 20001 
USA. October 29, 2013.

 
 
 
On Tuesday, July 22, 2014 9:06 AM, Jenny Narvaez <JNarvaez@nctcog.org> wrote:
Hi Kim,
 
TCEQ wished me to pass this along to you.  Please let me know if you need anything further.
 
Thanks,
Jenny
 
 
_____________
Jenny Narvaez | Principal Air Quality Planner
North Central Texas Council of Governments
Phone: 817.608.2342
Email: jnarvaez@nctcog.org

 


 
From: Shelley Naik [mailto:shelley.naik@tceq.texas.gov]
Sent: Thursday, July 17, 2014 11:13 AM
To: Jenny Narvaez; Walker Williamson; Stephen Davis; Chris Kite; Kathy Singleton; Kristin Patton; Chance Goodin
Cc: Chris Klaus; Donna Huff; Bob Gifford
Subject: RE: Top Flow Flowback
Hi Jenny,
 
Frac tanks temporarily at a drill site for flowback are not considered “stationary vessels” for the purposes of the storage rules in 30 Texas Administrative Code, Chapter 115, Subchapter B, Division 1.
 
However, there was a notice published in today’s issue of the Federal Register that the EPA is granting reconsideration of, proposing, and requesting comment on several issues, including provisions for well completions that clarify existing requirements for handling of flowback gases and liquids. Comments are due August 18, 2014, unless a public hearing is requested by July 22, 2014. If a hearing is requested on this proposed rule, the hearing will be held August 1, 2014 and comments are due September 2, 2014.
 
 
Please pass this EPA comment opportunity information along to Kim Feil.
 
Thanks,
 
Shelley Naik
Stationary Source Programs Team
Air Quality Division
Texas Commission on Environmental Quality
512-239-1536
 

 
 
From: Jenny Narvaez [mailto:JNarvaez@nctcog.org]
Sent: Wednesday, July 16, 2014 3:54 PM
To: Walker Williamson; Stephen Davis; Chris Kite; Kathy Singleton; Kristin Patton; Shelley Naik; Chance Goodin
Cc: Chris Klaus; Donna Huff
Subject: FW: Top Flow Flowback
All,
 
I reached out to Kim Feil to see if she had more information.  Below is what she just sent me.  Please let me know if you need anything else.
 
Thanks,
Jenny
 
 
_____________
Jenny Narvaez | Principal Air Quality Planner
North Central Texas Council of Governments
Phone: 817.608.2342
 
On Wednesday, July 16, 2014 3:48 PM,
kim feil <kimfeil@sbcglobal.net> wrote:
In the beginning stages of flowback, the mix of frac water, frac chemicals, and other NORM matter come back up and go into these flowback tanks that have open hatches (its the red, rural ones-see pic I attached they use here in urban areas).
IMG_5431
The fluid has hydrocarbons and is under pressure…a white fog is seen wafting into our neighborhoods and the odors have been described as a burnt sewery smell…heart palpitations have been reported upon breathing it by Arlington residents.  Some other workers have actually died from it.
Companies like Vapor Point  I believe, sell a ventless, pressurized flowback tank (I have a snap shot attached)
10439754_10204025681385273_1225773917_n
…drilling operator Devon has once reported that they tried these units in the Eagleford Shale? Was it Vapor Point tanks they used? I had a petition to make the frackers use closed tanks.
Urban Flowback Tanks is an example of a Best Available Emission Control Technology, but most Barnett Shale city gas well ordinances have language for the operators to only use “industry standard” or “reasonable” control technologies…(not BE$T control technologies).
Once the mix of fluid to gas and mud changes, the separators process the constituents and send them to different tanks and the gas go to the sales meter and the gas line for processing (aka green completions at end stage of flowback).
The EPA missed the beginning stages of flowback in their NSPS new rules, and so nobody is capturing these VOCs.
Thanks for following up on this. Please call me for any clarification or questions at 817 274-7257
Kim Feil

On a different note…back in 2010 I attended and was selected to speak at an Energy Resource Comittee meeting in Ft Worth. I remember them making copies of my petition. I forgot I listed some suggestions for Urban Drilling (however a ban still is the best plan)…

Below recommendations to Energy Resource Committee meeting. Courtesy Kim Feil! Thanks!

1) For the 70% needed on the hi-impact waiver, limit “one vote per owner”, “not per parcel owed”

2) Mandate drillers to report aggregate emissions from all their sites; mandate they apply for “New Source Review Permit”, “not a Permit By Rule”.

3) Baseline air test before the SUP is approved at the P&Z level to protect areas already high in emissions and to avoid toxic combinations of other sources

4) Clear language of green completions/closed loop systems that specify emission protections at each phase for drilling, compressor stations and pipelines.

5) Mandate fresh/clean (not reclaimed water) when initially drilling through the aquifer.


On Tuesday, July 15, 2014 4:27 PM, Jenny Narvaez <JNarvaez@nctcog.org> wrote:Hi Kim,NCTCOG staff contacted TCEQ, and their Stationary Source Programs team is not familiar with Top Flow Flowback. Can you please provide more information, and they are happy to look into it. You can provide it to me and I will correspond directly with them.Thanks,
Jenny_____________
Jenny Narvaez | Principal Air Quality Planner
North Central Texas Council of Governments
Phone: 817.608.2342
Email: jnarvaez@nctcog.org

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About Kim Triolo Feil

Since TX Statute 253.005 forbids drilling in heavily settled municipalities, I unsuccessfully ran for City Council Seat to try to enforce this. Since Urban Drilling, our drinking water has almost tripled for TTHM's. Before moving to Arlington in 1990, I lived in Norco’s “cancer alley”, a refinery town. It was only after Urban Drilling in Arlington did I start having health effects. After our drill site was established closest to my home, the chronic nosebleeds started. I know there are more canaries here in Arlington having reactions to our industrialized airshed (we have 55-60 padsites of gas wells). Come forward and report to me those having health issues especially if you live to the north/northwest of a drill site so I can map your health effects on this blog. My youtube account is KimFeilGood. FAIR USE NOTICE: THIS SITE MAY CONTAIN COPYRIGHTED MATERIAL THE USE OF WHICH HAS NOT ALWAYS BEEN SPECIFICALLY AUTHORIZED BY THE COPYRIGHT OWNER. MATERIAL FROM DIVERSE AND SOMETIMES TEMPORARY SOURCES IS BEING MADE AVAILABLE IN A PERMANENT UNIFIED MANNER, AS PART OF AN EFFORT TO ADVANCE UNDERSTANDING OF THE SOCIAL JUSTICE ISSUES ASSOCIATED WITH EMINENT DOMAIN AND THE PRIVATIZATION OF PUBLIC INFRASTRUCTURE (AMONG OTHER THINGS). IT IS BELIEVED THAT THIS IS A 'FAIR USE' OF THE INFORMATION AS ALLOWED UNDER SECTION 107 OF THE US COPYRIGHT LAW. IN ACCORDANCE WITH TITLE 17 USC SECTION 107, THE SITE IS MAINTAINED WITHOUT PROFIT FOR THOSE WHO ACCESS IT FOR RESEARCH AND EDUCATIONAL PURPOSES. FOR MORE INFORMATION, SEE: HTTP://WWW.LAW.CORNELL.EDU/ TO USE MATERIAL REPRODUCED ON THIS SITE FOR PURPOSES THAT GO BEYOND 'FAIR USE', PERMISSION IS REQUIRED FROM THE COPYRIGHT OWNER INDICATED WITH A NAME AND INTERNET LINK AT THE END OF EACH ITEM. (NOTE: THE TEXT OF THIS NOTICE WAS ALSO LIFTED FROM CORRIDORNEWS.BLOGSPOT.COM)
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