I fear both and Illinois is about to know the joy of them both.

Today (Tuesday, 12/3/13) is Day 19 of the IDNR Comment Period on Fracking.

Day 19 

Topic – Radioactivity in fracking operations:  Rules need to include requirements or standards 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”

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 proposed rules include no follow-up requirements or standards if testing shows radioactivity levels in flowback to be high.  In other words, these proposed rules treat flowback the same whether it is highly radioactive or not!  DNR knows that naturally occurring radioactivity material occurs in Illinois oil and gas operations.  See 62 Ill. Admin. Code secs. 240.860(e)(3), 240.861(k)(1)(C).

Revisions Needed:  The rules must specify how flowback AND produced water will be treated if they test positive for radioactivity.   The rules should also require that the requirements of the Illinois Low Level Radioactivity Waste Management Act be followed.

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