Category Archives: bad health effects

Illinois Fracking Will Fry Your Brain – But what is a little neurological damage amongst friends

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Please if you have children, move away from any fracking site immediately.

 

Get on the free bus from downtown Chicago to go to the Effingham public hearing on the lousy fracking rules on Monday, Dec 16th (leaves around 2pm and comes back around 12mn) the registration form for this bus is here: http://goo.gl/trFyMl  

 
Today, Saturday, 12/14/13, is Day 30 of Comments to IDNR on Fracking.  Today we want to talk about whether fracking is going to make you and those you love sick.  We hope you’ll make a comment. 
Topic: Volatile Organic Compound (VOC) Emissions
Section 1-53 of the regulatory bill requires that fracking operations be conducted in a “manner that will protect the public health and safety and prevent pollution.” But fracking is inherently dangerous and polluting.  Highly toxic Volatile Organic Compound or VOC emissions are generated by the fracking process and can cause irreversible neurological and or respiratory damage to children, adults, and other living things.
VOCs have scientifically been shown to cause asthma, cancer, and severe illnesses. In extractive states, the largest contributor to VOCs is usually the oil and gas industry.  This is the case in Colorado, where there have been many reported cases of illnesses from fracking pollution since the boom began.  Ozone-forming air pollution measured in Colorado is up to twice the amount that government regulators have calculated should exist.
Illinois can expect the same once fracking begins if the rules are not amended because, as currently drafted, the rules contain no best practice standards for mitigating VOCs.  In fact, Sec 245.900e of the Rules allow companies to be wholly exempt from the regulation of runaway natural gas and hydrocarbon fluids if the regulation isn’t “cost effective” or if it is “economically unreasonable.”
IDNR completely avoids defining “cost effectiveness” or “economically unreasonableness” – essentially allowing companies to define these terms for themselves. And we can assume that companies will make sure that they define it to their own benefit.
A cost/benefit analysis that only calculates private costs of companies while ignoring the social costs on the people and the environment will result in privatizing profits for big corporations while socializing losses for taxpayers, adding an unjust burden to local and state governments.
Solution:  The Department must quantify the cost of various kinds of emissions utilizing independent scientific studies on this issue.  Included in the quantification must be the health and environmental costs of emissions relative to the costs of capturing/reducing emissions.  Once quantified, the Department must enact rules that carry out the legislative intent of the General Assembly and ensure that fracking operations in Illinois will be conducted in a “manner that will protect the public health and safety and prevent pollution”
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Decatur Hearings Coming Up On December 17 – Everyone is welcome

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I do not know about the Dirty Dozen concept but the points are important and well made.

 

 

Four weeks ago today, IDNR released their weak fracking rules.  Many of you have been making comments every day.  THANK YOU!

For today’s comment, we’re switching things up a bit.  As we prepare for the Decatur, IL hearing and meetings with JCAR, we have put together what we are calling the “Dirty Dozen.” We believe these are the most egregious rules that pose a significant risk to public health, aquatic life, wildlife, or the environment. Read our “Dirty Dozen” and choose any one of them to make your comment for the day.  If you aren’t sure which radio button to choose or which Section is appropriate, just make your best guess.  IDNR tells us they will not reject a comment for being in the wrong Subpart or Section.

COME TO THE DECATUR IDNR MEETING

The Decatur hearing will be this coming Tuesday, December 17, at the Decatur Civic Center from 6:30-8:30.  Are you coming?   We have buses coming from Peoria, Bloomington and Springfield.  If you want to ride the bus, scroll down for information on the buses.

Will you testify?  Please consider testifying using one of the “Dirty Dozen” as the base of your testimony.  Choose a comment from the list, tell the IDNR Hearing Officer what is wrong with that Rule and then explain why this is personal to you in your own words.  For example,

  • “I am a nurse and the issue of keeping chemicals secret from medical professionals is an issue to me because it will impact the kind of care I can give someone who lives near a fracking operation and comes in with symptoms but doesn’t know what fracking chemical they were exposed to.”  OR
  • “I am a farmer and I need to protect my farmland from migrating water pollution from horizontal drilling legs that could run under my farm.” OR
  • “I am a grandmother and I want to make sure the water my grandchildren drink isn’t laced with chemicals and radioactivity.”

Translate the talking points into your own voice. Write it down so that you can submit it to IDNR at the end of the hearing.  Don’t worry about not being an expert on the subject.  You are an expert in your own life and IDNR needs to hear that citizens throughout Illinois aren’t happy about what’s happening with fracking.

BUSES

These are the times that buses will LEAVE for the hearing, so please, plan to arrive 15 minutes prior to departure with empty bladders and printed copies of your testimony!  Please eat before you come or bring a sack dinner.

  • 4:00 pm- Peoria – U.U. Church of Peoria – 3000 W. Richwood Blvd.
  • 5:00 pm- Bloomington – IPA Office -510 E. Washington
  • 5:00 pm- Springfield – First Presbyterian Church – 321 S. 7th St.

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So Illinois Is Gona Protect Me From Fracking – Not the way it is going

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When we got in the faces of the 5 renegade environmental groups, they claimed that IDNR would tighten up things to take in our concerns. So far that ain’t been ahappening. We will just have to see what happens after the comment period closes.
Today (Tuesday, 12/10/13)  is Day 26 of the Comment Period of IDNR.   Getting tired of making comments?  We understand.  But if we don’t fight, the industry will win because their fingerprints are all over these rules.  Fight back.  Make a comment today.
Today’s Topic:  IDNR’s Duties and Responsibilities to Protect the Citizens of Illinois
Comment:
In Section 1-130 of the regulatory statute, the legislature granted IDNR authority to adopt rules to carry out the legislature’s purposes.
There are at least two legislative purposes in the regulatory statute:
  1. To allow horizontal fracking in Illinois,
  2. To approve horizontal fracking conditionally based on the safeguarding of public health and public safety, and the protection of the environment.
This purpose is set forth explicitly in two places in the regulatory statute–Section 1-75(a)(2) and Section 1-53(a)(4).  IDNR has acknowledged 1-75 verbatim, in Section 245.800(2) of the proposed rules: “All phases of high volume horizontal hydraulic fracturing operations shall be conducted in a manner that shall not pose a significant risk to public health, life, property, aquatic life, or wildlife.”
But IDNR has changed the legislature’s language in Section 1-53(a)(4) of the proposed rules, lowering the standard explicitly created by the legislature.  Section 1-53(a)(4) of the legislation states: “The Department shall issue a high volume horizontal hydraulic fracturing permit, with any conditions the Department may find necessary, only if the record of decision demonstrates that: the proposed hydraulic fracturing operations will be conducted in a manner that will protect the public health and safety and prevent pollution or diminution of any water source.”  The key phrase there is”will be conducted”.  Clearly the intent of the statute is that fracking will only be allowed if it is conducted in a safe manner.
IDNR’s proposed Section 245.300 changes the legislative words “will be conducted” to “as proposed, are reasonably expected to be conducted”.  This lowers the standard and is inconsistent with the legislature’s stated purpose.  “Will be conducted” is a mandate; “reasonably expected to be conducted” is not.
If hydraulic fracturing outcomes in Illinois mirror effects of other states, we can “reasonably expect” that the industry will cut corners and violate standards.  There have been over 3000 violations in PA since 2009 and they are not minor violations.  They involve infractions such as:
  • 224 violations of “Failure to properly store, transport, process or dispose of residual waste.
  • 143 violations of “Discharge of pollutional material to the waters of Commonwealth.
  • 140 violations of “Pit and tanks not constructed with sufficient capacity to contain pollutional substances.
The residents of Illinois are depending on IDNR to protect their health, their safety, and the safety of their water, air, and soil.  IDNR needs to return the legislation’s intent and mandate that hydraulic fracturing operations will only be conducted in a manner that will protect the public health and safety and prevent pollution or diminution of any water source.”
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Mist Fracking, Foam Fracking And Gas Fracking – These are things I did not know

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But it sounds nasty to me. And then there is the use of Acid. This is really ugly stuff.

 

 

Today (Sunday, 12/8/13)  is Day 24 of the Comment Period of IDNR.   We’re almost half-way through the comment period.  Please keep making your comments daily!

Today’s Topic: Non-water and partial water fracks must be regulated based on risk, not volume

Comment:

The law defines “high volume” fracking based on the number of gallons of base fluid” (at least 80,000 gallons per stage and 300,000 gallons total).   While this definition may be applicable if the fracking base is a fluid such as water, it leaves a gaping hole when gas (e.g. nitrogen, carbon dioxide) or a mixture of gas and water (foam fracks, mist fracks), are used.  And defining high volume fracking this way is especially critical in relation to Illinois’ New Albany shale where other bases are likely to be used; nitrogen gas and mist fracking is already occurring just across the border in Kentucky’s New Albany shale.

Problem: Gallons are units of volume used to measure liquids.  But what if a liquid isn’t used in fracking?  Not all fracking base material can be measured by gallons.  If non-water base fluids are accounted for as liquid gallons, the gallonage total will fall below the threshold whereby the fracking operation will be considered “high volume hydraulic fracturing”, even though the operation is comparable in scale – and therefore risk – to a high volume water-based frack in terms of chemical use, pressures, or other measures.

Revisions Needed:

The Department needs to come up with an appropriate means to express the threshold of applicability as it applies to non-water fracks. The key parameter for developing a comparable threshold should be identifying comparable risk. Simply converting the water-based thresholds from gallons to cubic feet or another unit of volume appropriate to measure gases would be completely arbitrary and wholly divorced from the real environmental and health risks posed by such non-water fracks. Thresholds for gas-based fracks must be developed independently based on an evaluation of risk and field data from gas-based fracks.

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Frackers Or Radiation – Which do I fear most

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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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Snap, Crackle And Pop – Radiation from fracking makes the kids glow in the dark

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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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What Toxics Are In That Fracking Soup – Under this regulation we may never know

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Seriously, this means that they can brink “stuff” into this state with no inspection and inject it into our soils? That is off the charts.

 

Today (Sunday, 12/1/13) is Day 17 of the IDNR Comment Period on Fracking.  Thanks for hanging in there with us even on this holiday weekend!
Day 17 
Topic – The term “Competitive Value” is not defined but affords fracking operators the right to withhold chemical disclosure
Section 245.720(d) of the Proposed Hydraulic Fracturing Regulatory Act administrative rules, states: IDNR allows permit applicants to withhold chemical disclosure information under a claim of “trade secret” if they can establish that (1) the information has not been published, disseminated, or otherwise become a matter of general public knowledge, and (2) the information has competitive value.
Problems with this section:
  1. “Competitive value” is not defined in the various administrative code definitions.
  2. There is no IDNR administrative criteria provided which is the basis of “competitive value” other than, apparently, a self-identified one provided by the fracking operator.
Why these are problems:
  1. Undefined and catch-all allowances for generic “competitive value” open the door for any and all dangerous chemicals to be undisclosed simply based on the operators desire to do so.
  2. Individual ingredients in the various chemical products used during hydraulic fracturing cannot be considered trade secrets under the criteria “competitive value”. The regulations should be revised to state that information on file with IDNR must be disclosed to the public.
  3. Raising such an allowance for a fracking operator to not disclose potentially dangerous chemicals based on “competitive value” automatically gives them more power than the basic claim of the law which is to protect the environment of Illinois.
Revisions Needed:
  1. “Competitive value” must be fully defined within the rulemaking.
  2. Competitive value must not in any way supersede a determination of the public right to know and the basic legislative and Illinois Constitutional provision of a healthy and safe environment for its citizens.
  3. Any conflict between “competitive value” and the public right to know must be decided on the inherent protection of the citizens and the environment.
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Fracking Wildlife In Illinois – IDNR thinks it is a good thing

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Run little doggies, run for the hills, but if you are a fish you are pretty much dead.

 

Today (Saturday, 11/30/13) is Day 16 of the IDNR Comment Period on Fracking.  Thanks for hanging in there with us even on this holiday weekend!

Day 16  USED 11/30/13

Topic:  Definition of “Aquatic Life” is too narrow

  • Click the button: Subpart A: General Provisions
  • In the “Section” dropdown box, click:  245.110 Definitions
  • Submit your comment/s (below)
  • Click “Submit”

Section 245.110 Section 245.110 of the Proposed Hydraulic Fracturing Regulatory Act administrative rules, states: “Aquatic life” means all fish, reptiles, amphibians, crayfish, and mussels.

Problems with this section:

  1. This definition is too narrow and does not include many other species that may be important to an aquatic ecosystem.  Aquatic life cannot be understood apart from the larger aquatic ecosystem which sustains it.
  2. Freshwater ecosystems (limnology) not only include fauna, but also flora (plants), micro/macro invertebrates, oxygen levels and algae, for example.

Why these are problems:

  1. Exclusively focusing on a limited definition of “aquatic life” unnecessarily narrows the impact to the larger ecosystem that sustains it.
  2. By the time a fish kill occurs pollution caused by fracking will have reached a critical stage, causing havoc across the larger ecosystem.
  3. It neglects the biological criteria for the protection of aquatic life.

Revisions Needed:

  1. The definition of “aquatic life” must be broadened to include “aquatic ecosystems”.
  2. Specific scientific standards must be developed to include:  a) Biological standards, b) High quality water resources, c) Modified or limited water resources, and d) Stressor identification.

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Illinois Will Glow In the Dark – After Frackers scatter radiation all over the land

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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

  • 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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Frackers Could Take Over Your Town – Illinois cedes sovereignty to the extraction industry

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City and county governments?  We don’t care about your stinking City and County governments. Drill baby drill.

 

 

Today (Saturday, 11/23/2013) is Day 9 of the IDNR 45 day comment period on fracking.  You’re all doing a great job sending in your comments.  We’re a fifth of the way through the comment period.  Let’s keep the pressure on. 

Today’s comment is on the Local Control

Here’s what to do to make your comment today:

·         Click the button: Subpart A: General Provisions

·         In the “Section” dropdown box, click 245.210 Permit Application Requirements

·         Submit your comments (below)

·         Click “Submit”

Comment:

This section states that “when an application is made to frack a well site located within the limits of any city, village or incorporated town, the application shall state the name of the city, village, or incorporated town and be accompanied with a certified copy of the official consent for the high volume horizontal hydraulic fracturing operations to occur from the municipal authorities where the well site is proposed to be located.  No permit shall be issued unless consent is secured and filed with the permit application.”

This is excellent for municipalities but what about counties???

*  The intent of the legislation was to recognize that local units of government should have decision-making power regarding whether to allow fracking in their jurisdictions.  

*  This section demonstrates blatant disregard for the realities of the geography of fracking in Illinois regarding cities compared to counties.  Little if any fracking is anticipated within the cities of Carbondale, Marion, Decatur or other metro areas affected by the majority of fracking land leases.  If prior notification and an intentional process of permitting is important for metropolitan communities, why are the proposed rules silent regarding neighborhoods in counties and the families living there?

*  There is no substantive difference between a municipal or county government in Illinois in its powers other than the issue of Illinois Constitutional Home Rule.  However, the lack of county Home Rule has never preempted a county power to issue permits on mineral or oil extraction.  Numerous county governments have long histories and traditions in the permitting process regarding mineral and drilling industries. As the current fracking law is largely silent on the issue of county control, IDNR rules should err on the side of history and citizen decision-making. 

*  Counties and municipalities of government tax, employ law enforcement, provide social services and infrastructure.  The rules provide no explanation why citizens residing in counties of Illinois should have less input regarding fracking permits.  The regulatory differentiation between the rights of residents in municipalities vs. counties creates a group of second class citizens. These second class citizens have fewer rights in their ability to participate and ultimately determine the type and quality of energy extraction allowed in their neighborhoods.

*  There is no reasonable expectation that the personnel at IDNR have any better or more clear understanding of the will of citizens in counties regarding fracking permits than the residents themselves.  As the proposed IDNR rules envision municipalities empowered to decide fracking sites, what possible argument does IDNR have that it is better equipped or knowledgeable on the needs of residents living in Illinois counties? 

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