Today (Monday, 12/2/13) is Day 18 of the IDNR Comment Period on Fracking.  Welcome back from the Thanksgiving Holiday!  If you missed making comments, please go back through your e-mail and catch up.  We covered some important information over the weekend including inadequate bonds to cover accidents and corporate negligence (Thursday),  local control of water (Friday), definition of “Aquatic Life” (Saturday) and the definition of “Competitive Value” compared with the public’s right to know (Sunday.)  The next few days, we will be covering the topic of Radioactivity in depth.  It’s fairly technical information but very important.  So please make your comments every day!

Day 18 

Topic – Radioactivity in fracking operations: Produced Water Needs to Be Tested for Radioactivity

• Go to: http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx
• Click the button: Subpart H: High Volume Horizontal Hydraulic Fracturing Preparations and Operations (245.800-245.870)
• In the “Section” dropdown box, click 245.850 Hydraulic Fracturing Fluid and Hydraulic Fracturing Flowback Storage, Disposal or Recycling, Transportation and Reporting Requirements
• Submit your comment/s (below)
• Click “Submit”

Comment/Problem(s)/Needed Revisions:

Subsection (d)(1) of Section 245.850 provides for testing of fracking fluids only one time–during the early flowback stage–and only for “naturally occurring radioactive materials.”

Notably absent from these proposed rules is a requirement for the testing of “produced water”, the fluid that returns from the well during the later stage of production (after flowback).  Under the proposed rules, “produced water” can be stored on site and/or can be “recycled”, yet there is no testing requirement.

Naturally occurring radioactive material (NORM) is found in “produced water” also.  See Technologically enhanced naturally occurring radioactive materials in the oil industry (TENORM), Nukleonika 2009; 54(1):3?9, and sources cited therein, especially for TENORM in produced water in the U.S., available at http://www.nukleonika.pl/www/back/full/vol54_2009/v54n1p003f.pdf.  See also

NORM is also found on scale in oil pipes and on fracking equipment.  (See Kentucky Resources Council Proposes Comprehensive Plan For Investigating Radiological Contamination In Martha Oil Field.  August 11, 2005.   http://www.kyrc.org/webnewspro/112381723236086.shtml.)

IDNR’s definitions of “flowback water” and “produced water” are different.  The two are distinguishably different enough that they are treated as separate types of fluid by both the Hydraulic Fracturing Regulatory Act and by the DNR Rules.  Discharge of produced water onto the ground or into surface water or water drainage way is prohibited but it is not tested for radioactivity.  This despite the fact that this fluid will be in contact with the naturally occurring radioactive elements in the ground for a longer period that the flowback and that it is much more likely to be radioactive.

Problems:  Failure to test produced water for radioactivity is problematic for a variety of reasons including:

1. The health and safety of workers on the site who will be unaware of the levels of radioactivity they are being exposed to.
2. The health and safety of workers transporting produced water who will also be in the dark regarding the levels of radioactivity they will be exposed to.
3. The risk of storing radioactive material in tanks not created for storing radioactive materials.
4. The risk of “recycling” produced water—radioactivity cannot be removed by recycling.
5. The risk to the public in transporting radioactive materials

Argonne National Laboratory recently cautioned about radiological doses:  “It is commonly accepted that efforts should be undertaken at all times to keep radiological doses ‘as low as reasonably achievable,’ which is referred to as the ALARA principle or requirement.”  Overview of Radiological Dose and Risk Assessment (April 2011).  DNR is failing to even adequately test for radioactivity and therefore, will not know the levels of radioactivity.  How, then, can DNR adequately protect workers and the general public?

Revisions needed:

At a bare minimum, the rules should require that “produced water” be tested at two separate intervals across time for radioactivity.  This is already required in Pennsylvania. The rules should also require that the requirements of the Illinois Low Level Radioactivity Waste Management Act be followed.

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