Category Archives: fracking

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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Public Participation In Illinois – That is unheard of

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What the hell would the public know about their own self interest. Everybody outside of Chicago is just dumb hicks anyways.

Day 29 12/13/13 

Today’s Topic:  Who a potentially affected party must petiton in order to participate in a hearing.

Section 245.270 Public Hearings

The Act’s provision affording public hearings are critically important to ensuring that the public has the ability to fully understand hydraulic fracturing permits that may affect them, and challenge them if appropriate. We are therefore concerned that some aspects of the draft rules governing hearings could potentially undercut the robust public participation envisioned in the statute.

Section 1-50(b) of the Hydraulic Fracturing Regulatory Act says any person having an interest that is or may be adversely affected [by a fracking permit], can petition the Department for participation in a hearing.

But Subsection 245.270(a)(6) of the Rules raises the bar, requiring the request for hearing to be served upon the Hearing Officer, the Department, and the ap

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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Please For God’s Sake – Recycle the fracking fluid

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Why are we even messing around with this stuff. Colorado already demands recycling and Oklahoma make drillers bottle the natural gas. Why are we providing a lower standard of treatment of the Earth then other places.

 

Today’s Topic:  Discrepancies between the law and the rules on how long open-air pits can be used to store flowback.
  • 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: Section 245.850  Hydraulic Fracturing Fluid and Hydraulic Fracturing Flowback Storage, Disposal or Recycling, Transportation and Reporting Requirements
  • Submit your comment/s (below)
  • Click “Submit”
Section 1-75 of the Hydraulic Fracturing Regulator Act mandates that “excess hydraulic fracturing flowback captured for temporary storage in a reserve pit as provided in paragraph (2) of this subsection must be removed from the well site within 7 days.”
But Section 245.850 of the proposed rules states, “Any excess hydraulic fracturing flowback captured for temporary storage in a reserve pit as provided in Section 245.825 must be removed from the well site or transferred to storage in above-ground tanks for later disposal or recycling within 7 days after completion of high volume horizontal hydraulic fracturing operations.”
Problem:  The amendment of “after completion of high volume horizontal hydraulic fracturing operations” opens the door for the potential abuse of emergency pits.  Storage in closed tanks can be costly for the industry.  An unscrupulous operator wanting to cut costs could simply claim that there was more flowback than expected and end up using open pits for storage for the duration of the fracking process.
The clear intent of the statute is to ensure that wastewater is stored in tanks except in the emergency event of an unforeseeable overflow, in which case it is preferable that the overflow go to a pit than simply spill on the ground. But in such event, the overflow is expressly required in the statute to be removed within a week. Through omission and misinterpretation, the regulations are not implementing this statutory directive.
Section 245.210(a)(11), requires that an applicant submit a Hydraulic Fracturing Fluids and Flowback Plan.  The plan does not include requirements to ensure that tank capacity is accurately calculated. Without such method, there is nothing in the regulations to prevent operators from underestimating the size of the tanks they need, so as to make routine use of the reserve pit for the resulting overflows. Operators presumably have an economic incentive to do so in order to hold down the cost of tank storage.
Compounding this incentive is the Department’s weakening of the statutory directive that fluids deposited in a reserve pit be removed within 7 days (Section 1-75(c)(5). The regulations fail to require such prompt removal, allowing, at subsection 245.850(c), the overflow to remain in the reserve pits until 7 days “after completion of high volume horizontal hydraulic fracturing operations.” Certainly on a multi-well pad, hydraulic fracturing operations can continue for a month or more, meaning that the flowback fluid could be left sitting in the reserve pit, creating environmental risk, for much longer than a week.
Revisions needed:  First, require that drillers anticipate appropriate sized tanks for sufficient storage of flowback and produced water by establishing a method for tank capacity calculation. Second, clarify that wastewater must be removed from the pit within 7 days of the event that triggered the use of the pit rather than 7 days after fracking operations are complete, in accordance with the law.
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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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Illinois Permits Fracking – What the heck is wrong with that statement

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In Illinois, with in 60 days you are a super dooper presto oil drilling rig manly man. The state government in Illinois is not serious about regulating this very dangerous process. Be scared. Be very scared indeed.

 

Today (Monday, 12/9/13)  is Day 25 of the Comment Period of IDNR.   WE ARE HALFWAY THROUGH THE COMMENT PERIOD!!  Thank you–all of you–who have submitted comments.  We wish we could tell you that we’ve run out of things that are wrong with the Rules, but as we work our way through them, we are sadly finding many things that pose risks to public health and safey.  So keep your comments coming. 
Day 25 12/9/13 
Today’s Topic:  The 60-day review period should not begin until IDNR deems the application complete.
Comment:
Section 1-35 (f) of the Law states that the applicant must certify, “under penalty of perjury that the application is true, accurate, and complete.”
Subsection 245.230(d) & (e) of the Rules gives the Department 60 days to review and approve or reject the permit.  If, during that time, the Department deems the application is NOT complete, it is to notify the applicant in writing of the deficiencies and allow the applicant to correct them.
But it doesn’t stop the 60-day clock from ticking.
This is important because the 60-day review period runs parallel to the period of time the public has to prepare for a public hearing.  The rules, as written, invite abuse by unscrupulous applicants who could submit incomplete applications and withhold permit information until late in the process, thereby cheating the public out of valuable time needed to review the application and prepare for a hearing.
Revisions Needed:  This section should provide that the Department’s 60-day review period does not begin until the application is deemed complete by the Department. This would be allowable under the law as the law affords applicants the option of waiving the 60 days on its own accord or at the request of the Department.  If the Department finds the application to be incomplete, it could (and should) request the applicant waive the 60 day requirement, commencing it only after the application deficiency is cured.  Failure by the applicant to comply with this request should be viewed by the Department as grounds for rejecting the application and denying the permit.  The public comment period would, simultaneously be postponed to match the new timeframe.
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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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