Category Archives: industry apologists

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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Frackers Must Post Bonds To Drill – Doesn’t that mean they are going to do damage

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Yes and the damage they will do is a lot more than 50,000 $$$ they initially put up.

 

Today (Thursday, 11/28/13) is Day 14 of the 49-day Comment Period on Fracking.  On this Thanksgiving Day, we are thankful for your comments to IDNR.
Topic – Inadequate Bonding Requirements for Fracking Companies
  • Click the button: Subpart B:  Registration and Permitting Procedures
  • In the “Section” dropdown box, click:  245.220 Permit Bonds or Other Collateral Securities
  • Submit your comment/s (below)
  • Click “Submit”
Section 245.220 states, “The bond shall be in the amount of $50,000 per permit or a blanket bond of $500,000 for all permits.” (Section 1-65(a) of the Act)
Comment:  Plugging a well alone costs more than $50,000. In the study “Who Pays the Cost of Fracking?: Weak Bonding Rules for Oil and Gas Drilling Leave the Public At Risk”, PennEnvironment Research & Policy Center reported documented instances in which fracking wells have cost $700,000 or more to plug.  What is the motivation for the operator to not simply forfeit the bond when they shut down?  Furthermore, drilling companies typically frack a string of wells and not just one.  If they are cutting corners, using improper well-casings for example, or not sealing them correctly, the violation is likely to occur at each site.  One $500,000 bond for perhaps as many as 100 -150 well sites is as unacceptable as a $50,000 for one well site.
If the purpose of the bond is to protect the state from expenses incurred from an accident or violation, then the bond must be sufficient to cover those occurrences.  It makes no sense to offer a blanket bond—like some bargain basement “buy 2 pairs of socks and get a third pair free”.  Each well should be bonded individually and in the amount necessary to cover real and imagined damages as outlined by the PennEnvironment study.
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Frackers Free To Violate Illinois – According to the State of Illinois

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This was supposed to be the toughest set of regulations in the United States. This is an outrageous lie created by The Chicago Sellouts, better know as the gang of 5, the IEC, the NRDC, ELPC, the Sierra Club, and Faith in Place. They shall pay for this.

 

Today (Sunday, 11/24/2013) is Day 10 of the IDNR 45 day comment period on fracking.  Thank you for all of the comments you’re making!

Today’s comment is on what constitutes a “serious” violation.

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

This section of the rules states that every applicant applying for a permit must disclose to the Department  “all findings of a serious violation or an equivalent violation under federal, Illinois or other state laws or regulations in the development or operation of an oil or gas exploration or production site via hydraulic fracturing by the registrant or any parent, subsidiary, or affiliate of the registrant within the previous 5 years.”

  • What does IDNR define as a “serious” violation?  There is no guideline here making it easy for violators to claim that they didn’t report a violation because “we didn’t think it was serious.”  Instead, applicants should be required to disclose ALL violations alleged by public authorities and any fines or findings therefrom.
  • What is the reason for the 5 year time limitation?  When fracking violations potentially pose a threat to public health and safety, all previous violations and alleged violations should be considered when issuing a permit, regardless of how long ago they occured.

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IDNR Says Your Are Not Sick From Fracking Unless You Can Prove It

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So this regulation says essentially that you are never sick from fracking unless the Frackers and the IDNR agree that you are sick from fracking AND your doctor can prove it. Now of course you can’t prove it because they will not release a list of the chemicals  that they are using so you can test the environment for the chemicals so they can not say that they are naturally occurring. Got that?

 

Today is Day 8 of the 45 day Comment period on fracking in Illinois.  We start week 2.

Today’s comment is on the circular definition of an “affected patient.”

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

IDNR identifies the definition of an “Affected Patient” as “a person receiving health care services from a health professional for an illness or injury diagnosed by the health professional to be caused by exposure to any chemicals used in high volume horizontal hydraulic fracturing operations that are subject to a claim of trade secret by a permittee or contractor.”

PROBLEM:  This definition is circular: in order to learn what chemical was used, a physician must first test for that chemical so s/he can prove s/he has a right to disclosure of the proprietary chemical.  How can a doctor diagnose exposure to a secret chemical used in high volume fracking before s/he knows what the secret cheemicals are to test for?

Thank you!

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Illinois Department Of Natural Resources Is Incompetant – But we kinda knew that

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This was forwarded to me by Doctor Lora and other people have pointed out that this has been going on. This is why in my first post I said go to  this website:

http://www.ilagainstfracking.org/

They will deliver a printed copy to IDNR which gets you around the whole computer/internet thing.

AND Dr. Laura is suggesting that you send your comments to JCAR who must approve the final regulations before they become law. I am not sure how effective that would be but it takes so little time it can’t hurt. But still run them through IDNR repeatedly if you have to.

If you want to echo my remarks at JCAR, I think it would be very helpful, thanks,  L

 


Urgent — After two days of complaints from many residents concerned about fracking that their comments to the IDNR on the fracking rules weren’t going through, we learned that NO COMMENTS ON RADIOACTIVITY HAVE BEEN GOING THROUGH!   According to IDNR, there was a technical problem that has now been fixed, but that doesn’t address the fact that Comments from last Wednesday, yesterday and today did not get registered.
If they can’t get their website right, how are they going to get the rules right? 
Please share the comments below that were sent in by hundreds of residents with JCAR members, just in case the IDNR is trying to suppress comments about radioactivity in all fracking waste water and debris,

— General Summary of Rules on Radioactivity
Subpart H: High Volume Horizontal Hydraulic Fracturing Preparations and Operations (245.800-245.870)
245.850 Hydraulic Fracturing Fluid and Hydraulic Fracturing Flowback Storage, Disposal or Recycling, Transportation and Reporting Requirements

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:
The proposed rules do not include any standards or protocols to follow if testing of flowback water shows unacceptable levels of radioactivity. 
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.
The proposed rules do not require testing for added radioactive materials, like depleted uranium, which can be used in the perforation/fracturing operation.
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.

— Produced Water Needs to Be Tested for Radioactivity (same subpart-H, and section: 245.850)
Notably absent from this section is a requirement for the testing of “produced water”, the fluid that returns from the well later during production and is most likely to contain radioactivity. Under the proposed rules, “produced water” can be stored on site and/or can be “recycled”, yet there is no testing requirement.
Naturally occurring radioactive material (NORM) and technologically enhanced naturally occuring radioactive material are both found in “produced water”. See Technologically enhanced naturally occurring radioactive materials in the oil industry (TENORM), Nukleonika 2009; 54(1):3?9, and sources cited therein, especially for TENORM in produced water in the U.S., available athttp://www.nukleonika.pl/…/full/vol54_2009/v54n1p003f.pdf. See also
NORM is also found on scale in oil pipes and on fracking equipment. (See Kentucky Resources Council Proposes Comprehensive Plan For Investigating Radiological Contamination In Martha Oil Field. August 11, 2005.http://www.kyrc.org/webnewspro/112381723236086.shtml.)
IDNR’s definitions of “flowback water” and “produced water” are different. They are treated differently by both the Hydraulic Fracturing Regulatory Act and by the DNR Rules. The Department knows that produced water will be in contact with the naturally occurring radioactive elements in the ground for a longer period that the flowback and that it is much more likely to be radioactive. Therefore it should require it to be tested and handled accordingly.
Problems: Failure to test produced water for radioactivity is problematic for a variety of reasons including:
The health and safety of workers on the site who will be unaware of the levels of radioactivity they are being exposed to.  The health and safety of workers transporting produced water who will also be in the dark regarding the levels of radioactivity they will be exposed to. 
The risk of storing radioactive material in tanks not created for storing radioactive materials.
The risk of “recycling” produced water—radioactivity cannot be removed by recycling.
The risk to the public in transporting radioactive materials
Argonne National Laboratory recently cautioned about radiological doses: “It is commonly accepted that efforts should be undertaken at all times to keep radiological doses ‘as low as reasonably achievable,’ which is referred to as the ALARA principle or requirement.” Overview of Radiological Dose and Risk Assessment (April 2011). DNR is failing to even adequately test for radioactivity and therefore, will not know the levels of radioactivity. How, then, can DNR adequately protect workers and the general public?
Revisions needed:
At a bare minimum, the rules should require that “produced water” be tested at two separate intervals across time for radioactivity. This is already required in Pennsylvania. The rules should also require that the requirements of the Illinois Low Level Radioactivity Waste Management Act be followed. 

— Rules need to include requirements or standards when radioactivity is found (same subpart-H and section:245.850)
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.
 
Sincerely, 
Frack Free Illinois
contact, Dr. Lora Chamberlain
drlora2@yahoo.com
773-486-7660

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McADA Coming To Destroy Illinois – With all their fracking support services

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So what? So I am picking on the frackers by company name now. That is too bad. What have I got to lose?  Here is the second comment that IPA released. I am leaving the dates on their actual emails for authenticity’s sake.

 

Today (Monday, 11/18/2013) is Day 4 of the IDNR 45 day comment period on hydraulic fracturing, aka “fracking.”  Will you please send IDNR a comment today?  It will take less than 5 minutes of your time and we will walk you through the process.  If you are opposed to fracking and worried that the weak regulatory bill will not protect Illinois residents and the environment, please take action.

Today’s comment is on the lack of Studies, Reports, or Underlying Data Used to Compose Rulemaking

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

This comment is in reference to Page 3, Paragraph 6 of the Proposed Hydraulic Fracturing Regulatory Act administrative rules, which states: “Published studies or reports, and sources of underlying data, used to compose this rulemaking: None”.

Simply put, the State of Illinois cannot have sound regulation without good data.

There is significant need for further study of horizontal hydraulic fracturing technology prior to it’s use in the State of Illinois. If the technology was as safe as the industry is claiming, why do there continue to be so many accidents and violations in states where fracking is already occuring?

Suggested resources include the twenty-four (24) pages of “References” included in U.S. EPA’s December 2012 Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources.

See: U.S. EPA: Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources: Progress Report, (EPA 601/R-12/011 | December 2012), available at: http://www.epa.gov/hfstudy.

We would love it if you would let us know if you made a comment today!  And please feel free to call us with questions, comments, or to volunteer your time at (309) 827-9627.  Please share this with others you know and encourage them to make comments too.

In solidarity in the struggle for environmental justice,

Your friends at IPA

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Fukushima – The ongoing threat

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While it is true that this “underground river of water” or what ever it is, is troubling. It is also clear that the bloggers and the fear mongers also want to have an end of the world hissy fit. The truth probably lies in the middle somewhere, BUT the fact that this is 2 and 1/2 years later is both dangerous and unacceptable. I lay this one at the foot of the antiquated class structure of Japan and its notion that deference is the only honorable approach to major social conflicts. This is at its heart a cultural conflict between the business community and the government which the business community wants to win. Such a win could end us all and the fact that the Japanese government is just now catching on is frightening.

http://www.washingtonsblog.com/2013/08/official-tepco-plan-could-cause-fukushima-reactor-buildings-to-topple.html

Official: Tepco Plan Could Cause Fukushima Reactor Buildings to “Topple”

Posted on August 7, 2013 by WashingtonsBlog

Japan’s Nuclear Accident Response Director Warns that Tepco’s Actions Might Cause Reactor Buildings to Collapse

Tepco’s ill-considered efforts to change soil permeability and water flow have caused severe problems at the site … including highly radioactive groundwater bubbling up to the surface.

NHK notes:

The vice governor of Fukushima Prefecture has asked the government to take the lead in handling the matter and stop the leakage. Masao Uchibori told an official from the Nuclear Regulation Authority that some of Tepco’s measures have increased the risk of further leaks.

The Wall Street Journal’s Michael Arnold says:

Obviously this is a massive public health issue … if it gets into the ocean obviously this could be spread throughout the Pacific, could also get into the food supply.

Background here and here.

But there is another – stunning – threat.

Specifically, BBC points out:

Engineers are now facing a new emergency. The Fukushima plant sits smack in the middle of an underground aquifer. Deep beneath the ground, the site is rapidly being overwhelmed by water.

What happens when you pour hundreds of thousands of tons of water (400 metric tons each day times 2.5 years times 365 days in a year equals 365,000 metric tons of water)  onto soil which sits above a massive aquifer?

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Tilting sinking buildings is not good. Go there and read. More next week.

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Fracking Should Be Banned In Illinois – But apparently the frackers have decided to forge ahead

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I got an email from Southern Illinois that said 30 big rigs had rolled through town yesterday morning. I figure that that is enough for 2 wells. It seems like some drilling company has decided to “go for it”. Which makes sick and disgusting sense. Many of the leases die at the end of April. I suspect that these will be test wells, because no one knows what is down there. It takes about  7 days to to drill a well and frack it. That would have the wells beginning to come in as the lease expires. This is what I said in print.

Thursday, April 11,2013

Letters to the Editor 4/11/13

Fracking and litter control act

By Letters to the Editor

 

FRACKING STINKS

I am writing to argue for a moratorium against fracking in Illinois (SB 1418). Chicago environmentalists argue that “fracking is going to happen anyway.” That is a total capitulation to the industry. The bill that the environmentalists endorse (HB2615) is amazing in the things it does not prevent. It does not force the frackers to recycle their water, allows for methane flaring, allows wells within 300 feet of water sources, allows wells within 500 feet of a house, does not allow adequate testing of produced waters especially for radiation and then allows that waste to be deep well injected and finally allows for the state to overrule counties and municipalities who do not want fracking or more protective measures.

Many states have tried to establish hydraulic fracturing regulations that would allow the industry to drill safely. The problem is regulations do not work. The industry always violates the regulations and when caught pays the fine as part of standard operating procedure. These violations include injecting radioactive water underground, open pit storage of fracking and waste waters even where not permitted, the production of toxic fumes and the sickening of residents, well water contamination and the direct dumping of toxic water into springs and streams. They have gone so far as to sell toxic water to county townships to suppress dust in the summer and to de-ice roads in the winter as if that was safe. Homeowners are duped into selling mineral rights without being told that it will make their houses impossible to sell and wreck their mortgages. In Pennsylvania their violations include:

– 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.”

This does not include the actual damage that they do to the environment, like damaging the roads where they work, and flaring the natural gas that should be harnessed as a fuel source and the constant noise pollution that the above activities produce. I was visiting a friend in Colorado when such a well was put in and the noise and smell alone were enough to sicken me.

Doug Nicodemus
Riverton
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Phase Nuclear Power Out Of The USA – Finally somebody had the guts to say it

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This is so big that I just had to find the original source. Once I got to the source the article did not carry the same headline as the inflammatory piece from Washington Blog but in the last paragraph he does imply phasing out the nukes. He also points out that no upgrades have been ordered in response to Fukushima nor included in the new licenses issue. This IS the insanity of Nuclear Generation of electricity.

http://peakoil.com/alternative-energy/former-u-s-nuclear-chief-american-nuclear-plants-should-be-phased-out-cant-guarantee-against-accident-causing-widespread-land-contamination

But this is what the guy really said.

http://ajw.asahi.com/article/0311disaster/fukushima/AJ201303140050

 

INTERVIEW: Former U.S. nuke watchdog chair says regulators must stay independent

March 14, 2013

By SHIRO NAMEKATA/ Correspondent

As it is poised to impose strict regulatory measures on the operation of nuclear power plants, the Nuclear Regulation Authority is increasingly met by opposition that it is making the resumption of plants that are currently offline virtually impossible.

In a recent interview with The Asahi Shimbun in Washington, Gregory Jaczko, former chairman of the U.S. Nuclear Regulatory Commission (NRC), said it is crucial for a nuclear watchdog to stay independent from the nuclear industry.

Jaczko, who, unlike his four colleagues, opposed the first new construction and operation of a nuclear plant in the United States since the 1979 Three Mile Island accident, also discussed the future of nuclear energy. Excerpts from the interview follow:

 

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