Category Archives: stewardship

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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Water Is Precious – Why would we mix it with toxics and then pump it under ground

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The whole United States is drought prone now. We dirty up to much fresh waster. We drink alot through inefficient drinking water systems. Springfield’s ancient system wastes as much as it delivers and we just came through a serious drought. Now we want to waste water on fracking? Really? No Way!

 

Today (Friday, 11/29/13) is Day 15 of the IDNR Comment Period on Fracking.  Please don’t miss making a comment today on the very important topic of water!

Topic – Inadequate Water Plans and Local Control of Water in Permitting Process

  • Click the button: Subpart B:  Registration and Permitting Procedures
  • In the “Section” dropdown box, click:  245.210 Permit Application Requirements
  • Submit your comment/s (below)
  • Click “Submit”

Subpart B:  Regulations and Permitting

Section 245.210 Permit Application Requirements

Section 245.210 requires permit applicants to submit: a Water Source Management plan: “If fresh water is anticipated to be used in the high volume horizontal hydraulic fracturing treatment, a water source management plan that shall include the following information:” (source of ground or surface water, how much water to be used, months of use, methods to minimize fresh water use, methods used to minimize adverse impact to aquatic life).

Problems with this section:

  1. While there is a required water management plan, this plan does not require application to local municipal, water district or other governmental control units requesting use of their ground or surface water resources.  In fact, if fracking is allowed, local government has no authority to deny water to a frack well operator, even in the case of drought.
  2. There is no process for sharing the frack operator’s water plan with other state or regional agencies responsible for water usage (e.g. Illinois EPA, East Central IL Regional Water Supply Planning Committee) for their input on whether the plan is adequate, and how usage relates to possible drought situations.
  3. There are no minimum regulatory thresholds regarding the amount of water to be used, the impact of water use given drought situations, actual impact on aquatic life, impact on existing human, industrial and agricultural water immediate needs, and potential future impacts.

Why these are problems:

  1. The IDNR report The Drought of 2012, March 2013 identified:
  1. In 2012, the 12 counties of southern IL–where the majority of fracking leases have been obtained–experienced “D4 drought – exceptional”, the most severe drought rating.  From July to December 2012 the area was in continuous drought.
  2. Two of three local areas identified as “at risk public water supply” are in potential frack operation counties (Macon, Johnson, IL).  These counties were identified in an IL EPA 2012 drought report as having Community Water Systems most stressed by the drought.
  1. A report by the East Central IL Regional Water Supply Planning Committee identified:
  1. Springfield has a greater than 50% probability their water system will be unable to meet projected water use with a drought of record.
  2. By 2020, Bloomington and Decatur’s water systems will be inadequate to meet demand.
  1. The average water use by a frack operator is significant and will have an impact on water usage.  According to federal EPA, the average frack uses 4.4 million gallons of water.  And wells can be fracked multiple times.

Needed changes:

  1. Any governmental unit that involves itself in local or regional water issues must review the frack operator water source management plan with the power to affirm, reject or modify the plan.
  2. If a county or geographic area is identified as being in a drought, frack operations will cease.
  3. IDNR must develop scientifically based high minimum, specific standards of water usage protecting existing human, agricultural and industrial use.  A frack operator’s water source management plan must adhere to these formal standards.

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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 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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Fracking And Water Quality In Illinois – We don’t want any burning drinking water here

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For now I have run out of thoughts about how bad the original law was and how terrible the rules coming from it are now.

 

Today (Tuesday, 11/26/13) is Day 12 of the 45-day Comment Period on Fracking.  We’re receiving great feedback from so many of you.  Thank you for writing comments and enlisting others to write too.  You rock!

You know the drill.  Here’s what to do to make today’s comment:

  • Go to: http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx
  • Click the button: Subpart F: Water Quality (245.600-245.630)
  • In the “Section” dropdown box, click 245.600 Water Quality Monitoring
  • Submit your comments (below)
  • Click “Submit”

Section 245.600(b)(1) of the proposed rules provides for the testing and monitoring of water sources within 1,500 feet of the well site.  Among the many problems with the monitoring provisions, the proposed rules do not provide for testing along the horizontal leg of the well bore, which can extend for up to two miles from the well site.  This is a reckless disregard of the known risk of the underground migration of toxic fluids from a horizontal well bore, especially when hydraulic fracturing involves the use of explosive charges and especially in areas known for the risk of higher-magnitude earthquakes.

In a report issued on September 5, 2012, the U.S. Government Accountability Office acknowledged this risk:

“Oil and gas development, whether conventional or shale oil and gas, pose inherent environmental and public health risks, but the extent of these risks associated with shale oil and gas development is unknown, in part, because the studies GAO reviewed do not generally take into account the potential long-term, cumulative effects.”–From: Information on Shale Resources, Development, and Environmental and Public Health Risks, U.S. Government Accountability Office, GAO-12-732 (2012), “What GAO Found”.

The agency mentioned specifically the risk of underground migration of toxic gases and chemicals:

“[A] number of studies and publications GAO reviewed indicate that shale oil and gas development poses risks to water quality from contamination of surface water and groundwater as a result of erosion from ground disturbances, spills and releases of chemicals and other fluids, or underground migration of gases and chemicals.”  (Emphasis added.)

Water testing and monitoring should be required all along the length of any horizontal well bores.

(The Government Accountability Office is an independent, nonpartisan agency that works for Congress.)

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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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