Rice Krispies!  But you could find your kids in the dark.

Today (Wednesday, 12/4/13) is Day 20 of the IDNR Comment Period on Fracking. 

Day 20 

Topic – Radioactivity in fracking operations:  Rules need to include testing for all types of radioactive material, including depleted uranium, and set requirements and standards for when radioactivity is found.

• 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)/Revisions Needed:

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.”

Problem:  The limited radioactivity testing requirement in this section does not adequately protect Illinois residents from the spread of dangerous radioactive materials.  The statute and the proposed rule call for the testing of flowback (and not produced water) for “naturally occurring radioactive materials”.  However, the term “naturally occuring” is not defined in the statute or the proposed rules;  DNR could interpret the quoted term so that testing will be required only for the specific radioactive materials that are expected to be found naturally in the subsurface at the well site.  Depleted uranium would not be “naturally occurring” at the well site, so it will be undetected by the proposed testing.

Depleted uranium (DU) is a highly dangerous radioactive material with a half-life of 4.5 billion years.  It is a waste product left over when uranium is modified to produce fissionable material for nuclear reactors and weapons.

We know that at least one of the major actors in the fracking industry has incorporated Depleted Uranium into its plan for perforating the gun assembly (for use in a wellbore) in horizontal fracturing operations. (See U.S. Patent No. 2011000069, “perforating gun assembly for use in a wellbore *** wherein the secondary pressure generator is selected from the group consisting of *** depleted uranium”; assignee of patent: Halliburton Energy Services, Inc.)   Note that, in this case,  radioactive material would be “added” radioactive material, not “naturally occuring.”

Revisions Needed:

In order to protect the public health and safety and to preserve the health of our environment, DNR must require specific testing for DU among other types of radioactive material in flowback and in produced water and set standards and requirements for when radioactivity is found.

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