Category Archives: self inflicted wounds

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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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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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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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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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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A Whole Lot Of Shaking Could Go On – Those old Sky Scrapers could come a tumblen down

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It is true none of the tall buildings in either St. Louis or Memphis are even earthquake resistant let alone earthquake proof. To top that off they are built on alluvial soil. Then there are the bridges across the Mississippi, Nebraska and Ohio rivers.So even a moderate earthquake in the area could be its own little disaster movie.

Today (Tuesday, 11/19/2013) is Day 5 of the IDNR 45 day comment period on hydraulic fracturing, aka “fracking.” 
We’re asking for a little something extra from you today.  In addition to making today’s comment, which is about fracking-induced earthquakes (see below), will you also sign a petition that would allow Johnson County–which is in the heart of the New Madrid fault zone–to assert its right to local self-government in order to ban corporate fracking?  This would be a test case for Illinois and might open the door to local county governments banning fracking.  They need signatures.  You can sign here:
Today’s comment is on Seismicity: Insufficient Protection, Two Types of Risk
Here’s what to do to make your comment today:
Comment:  In subsection (a), “Applicability”, DNR proposes that this rule apply ONLY to Class II  injection wells, not to any other.  DNR has not proposed any rules for fracking wells.  This is insufficient protection of the population in southern Illinois where citizens are at risk of a major earthquake.  Southern Illinois sits above two active seismic zones: the New Madrid and the Wabash Valley.
There are two distinct earthquake risks: (1) the risks from injection wells inducing earthquakes that would not otherwise occur and (2) the risks of substantial injuries and damages created when the toxic fracking fluid left in the ground, in pipelines, and in wells (injection and otherwise) is let loose as a result of a major earthquake.  There are NO rules establishing guidelines for stopping fracking wells in the event of earthquakes, and NO considerations for siting any wells specifically in active seismic zones.  That omission is a reckless disregard for the safety of Southern Illinois residents, their property, and the ecology of the region.
Furthermore, in light of recent studies (see below), the risk of earthquakes can extend far beyond local areas.  See:
  • http://www.earth.columbia.edu/articles/view/3072 :  A new study is the latest to tie a string of unusual earthquakes, in this case, in central Oklahoma, to the injection of wastewater deep underground. Researchers now say that the magnitude 5.7 earthquake near Prague, Okla., on Nov. 6, 2011, may also be the largest ever linked to wastewater injection. Felt as far away as Milwaukee, more than 800 miles away, the quake—the biggest ever recorded in Oklahoma–destroyed 14 homes, buckled a federal highway and left two people injured.
  • http://geology.gsapubs.org/content/early/2013/03/26/G34045.1
  • http://www.usgs.gov/newsroom/article.asp?ID=3706&from=rss#.UohRF40hRL8  “Why America’s Heartland is Earthquake Country”, United States Geological Service, September 30. 2013
  • “Enhanced Remote Earthquake Triggering at Fluid-Injection Sites in the Midwestern United States”, Nicholas J. van der Elst et al., DOI: 10.1126/science.1238948, Science 341, 164 (2013).
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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Chevron Brings Good Fracks To You – Illinois is going to get the heck fracked out of it

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Will Chevron have wells in Illinois? Probably not.  They are to busy illegally fracking their wells off of California’s shoreline. But chatting them up can’t hurt.

Day 1 on 11/15/13

Topic: Who can and can’t testify and public hearings when fracking permits are requested. 

 

Go to:   http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx

Radio Button: Subpart B: Registration and Permitting Procedures (245.200-245.270)

 

Comment: Because air and water travel freely, IDNR should not limit comments during public hearings to individuals living within 1500 feet of wells.  Toxins can travel far beyond 1500 feet via air and water.  Therefore, any person, regardless of where they live, should be allowed to testify.

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