All fossil fuels contain radiation somewhere in their masses. In other words in any given coal deposit there will be radioactive hotspots. The same is true of oil and natural gas. So with Fracking you can never tell when you will hit on of those hotspots in the shale. What this means is that all disposal sites for all the debris from the fracked wells must have radiation detectors to guarantee that any radioactive materials are deposited in sites designed for such materials.

Today (Wednesday, 11/27/13) is Day 13 of the 45-day Comment Period on Fracking.  We hope you’ll take a minute out of your holiday preparations to submit a comment to IDNR about fracking and radioactivity.

Topic – Radioactivity in fracking operations: More loopholes

• 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:  Subsection (d)(1) of Section 245.850 provides for testing radioactivity only one time–during the early flowback stage–and only for “naturally occurring radioactive materials”.  The problems with this are identified below.

Problems:

1. The proposed rules do not include any standards or protocols to follow if testing of flowback water shows unacceptable levels of radioactivity.
2. The proposed rules do not require the testing of “produced water”, which is the water produced from a well in conjunction with oil or natural gas production.  This is where radioactivity is most likely to show up.  It should be noted that while these Rules have been purported to be the strongest in the nation, PA law requires the testing of produced water at two separate intervals.
3. The proposed rules do not require testing for added radioactive materials, like depleted uranium, which can be used in the perforation/fracturing operation.
4. The proposed rules do not test work areas for levels of radioactivity that would call for OSHA standards of occupational safety.

These deficiencies, cumulatively or singly, would pose a significant risk to the public health and safety, property, aquatic life, and wildlife, in violation of section 1-75(a)(2) of the Hydraulic Fracturing Regulatory Act.

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Go there and comment. More today.

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