Category Archives: stewardship

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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IDNR Cancels Hearing In Effingham – Day 7 of comments released here

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The weather outside is frightful. Especially in Southern Illinois. So now you have all the time in the world to post comments to IDNR’s website.

 

Effingham, December 5, Holiday Inn 6:30 PM – CANCELED
• Decatur, IL December 17, Decatur Civic Center 6:30 PM
• Carbondale, December 19, SIUC Student Center 6:00 PM

Today is Day 7 of the 45 day Comment period on fracking in Illinois.  You’ve made it to the end of your first week.  Thank you for your comments!
Today’s comment is on the lack of provisions to address fracking in a tornado-ridden state.
Here’s what to do to make your comment today:
Comment:  Number of draft regulations proposed by Illinois Dept. of Natural Resources describing safety measures regarding tornado strikes on fracking sites: ZERO.  Number of tornados in Illinois in the last 10 years: 674.
Historically, the number and intensity of tornadoes in IL is very high.  “In fact, Illinois has experienced some of the worst tornados in US history.” Dr. Jim Angel, Illinois State Climatologist.
Every county in Illinois has had multiple tornados as demonstrated by the maps in the following links:
A big swath of Washington IL was flattened by a tornado on Sunday, 11/17/13. What would have happened if this tornado had hit an area of the state covered in fracking sites?  Debris from the tornado has been found over 150 miles away.  Imagine if that debris had included “temporarily” stored flowback water or tanks filled with frack fluid or produced water?
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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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510 E. Washington St. Suite 309
Bloomington, IL 61701
United States

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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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Fracking Will Set Off The New Madras Fault – In Illinois a whole lot of shaking going on

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This whole earthquake thing has me shaking in my boots. No really. The last time New Madras went off the Mississippi River ran backwards and two mammoth lakes in Kentucky were created. There was no St. Louis or Memphis to be devastated. This is a big deal.

USED on Day 2 on 11/16/13

Topic:  Fracking and Seismic Activity (Earthquakes) 

Radio button: Part 240 : Seismicity (240.796)

Use any of the comments below related to when fracking causes earthquakes (“induced seismicity”)

NOTE: Every topic address must be entered as a separate comment.

·         COMMENT:  The Rules contain language about earthquakes and, on a broader level, they also assume that fracking indeed causes earthquakes.  The rules describe a whole series of fracking created earthquake levels of intensity. Why would the state allow any business activity that includes the real possibility of it creating earthquakes when done in an otherwise proper manner – especially in a geography known for major earthquakes?

·         COMMENT:  The rules are silent regarding broader concerns regarding how fracking created earthquakes will affect existing earthquake prone communities.  There is no mention of scientific review or study of the effect of fracking earthquakes within the Wabash Valley and New Madrid Seismic Zones.  The Illinois Emergency Management Agency identifies southern IL with its most severe earthquake zone ratings of “Destructive “and “Ruinous”.  How does IDNR justify allowing any fracking in these areas when industry best practices say there should be no fracking in seismic zones?

·         COMMENT: Rules define various intensities of fracking caused earthquakes by a color code system.  Enforcement doesn’t begin until “yellow light alert”, (a magnitude of at least 3.0 but less than 5.0).  This color coding system does not appear to be used by the federal USGS, the federal agency responsible for monitoring earthquakes. Why would IDNR use a system not used nationally?  What is the purpose of IDNR’s color coded system and what value does it add to protect citizens who might be affected by said quakes?

·         COMMENT: A fracking site can be responsible for creating up to 4 earthquakes up to a level of 4.9 magnitude WITHOUT a mandatory shut-down order by the state. A 4.9 earthquake is a serious and newsworthy event – (USGS description: “Sensation like a heavy truck striking building.  Standing motor cars rocked noticeably.”)  What justification does IDNR to allow this?

·         COMMENT: Mandatory shut-down of a site is based on a patchwork of multiple earthquakes at multiple times with varying intensity.  For example, if an earthquake caused by fracking “causes significant damage” or a magnitude of 5.0 or greater the state will shut-down the frack site.  A 5.0 earthquake is described by USGS as “Felt by all, many frightened.”   The rules use a dangerous, high threshold of earthquake intensity for a mandatory shut-down.  The fracking caused earthquake literally has to frighten people or break something before the state will step in.  What is the justification for such a high threshold?

·         COMMENT: If a shut-down order is made, the fracking company gets a hearing, the purpose of which is to “mitigate induced seismicity events near the permitted well”.  To “mitigate” is to minimize, not eliminate earthquakes caused by fracking.  As with the overall message of the earthquake rules, the intent appears to not eliminate earthquakes caused by fracking but actually permit them.  What does IDNR have to say to justify this?

·         COMMENT:  The penalty for failing to attend an earthquake hearing or continuing to frack after causing a serious, reported earthquake is $50 for a first time violation.  The rules define these violations as “Administrative penalties”.  This amount is a little less than the cost of a dinner and a movie.  Even with 4 or more earthquake violations, the maximum fine is only $500, arguably an acceptable business expense.  How is this justifiable? 

·         COMMENT:  Will fracking companies be held responsible for all monetary damages caused by earthquakes?

·         COMMENT: If the frack site continues to operate in violation of a state order regarding it creating earthquakes the minimum fine is $100.  Who is making up these ridiculously industry-slanted rules?

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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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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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510 E. Washington St. Suite 309
Bloomington, IL 61701
United States

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Solid State Lighting – Why state of the art energy solutions are not applied

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Residential energy conservation has stagnated somewhat in the last 3 or 4 years. I do not know what the dampers are, whether it is price or attitude for instance. New houses are a lot more efficient but the efforts to improve existing housing stock have stalled. Here is an article about those latest techniques.

http://www.nyserda.ny.gov/Energy-Efficiency-and-Renewable-Programs/Residential/Emerging-Technologies-and-Accelerated-Commercialization.aspx

Emerging Technologies and Accelerated Commercialization (ETAC) in the Residential Sector

Opportunities to achieve energy-efficiency gains in the residential sector beyond traditional building and retrofit techniques have been limited by underutilization of emerging technologies that are commercially-available, but face barriers to widespread adoption in the industry. Technologies and techniques such as solid state lighting, lighting controls, home energy management systems, smart-grid integration, micro-combined heat and power, and super insulation have proven benefits. But they have seen limited market adoption, due to obstacles such as upfront costs, consumer and builder awareness and the lack of infrastructure support, including activities such as supply chain development, sales training and installer certification.

The ETAC initiative seeks to address the barriers to market acceptance by facilitating in-field demonstrations and the subsequent technology transfers. Widespread, large-scale demonstrations will incorporate these technologies into energy-efficiency projects, where the savings potential will be monitored and validated. In parallel, other marketplace needs will be addressed, such as the development of a training curriculum for designers and specifiers, installer-certification standards, consumer-education materials, and maintenance processes. Following the demonstration period, results will be communicated to the marketplace via various means such as case studies, presentations, and webinars.

While this specific initiative is focused on emerging technologies in the residential sector, NYSERDA will also demonstrate emerging technologies for the multifamily and commercial/industrial sectors through parallel ETAC initiative

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Germany Gets 20% Of Its Power From Renewables – After the renewable gold rush

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I thought I would start us out with a song.

http://www.youtube.com/watch?v=NOMaqe0LOmo

The days when all the lies are proven false is right here and right now. Wind, solar and geothermal can replace coal gas and oil. And hthey can do it in the industrial heartland. It is the future and ain’t it grand?

http://uk.reuters.com/article/2011/10/17/us-germany-renewables-boom-idUKTRE79G0N420111017

 

Analysis: Renewable “gold rush” powers Germany’s north shore

 

 

By Erik Kirschbaum

ROSTOCK, Germany | Mon Oct 17, 2011 6:04am BST

(Reuters) – Renewable energy has created a “gold rush” atmosphere in Germany’s depressed north-east, giving the country’s poorhouse good jobs and great promise.

The natural resources attracting investors and industry are of a simple variety: wind, sunshine, agricultural products and farm waste such as liquid manure.

The rush to tap green resources in Mecklenburg-Vorpommern state is reminiscent of the frenzies that came with gold or oil discoveries in past centuries. The buzz can be felt in towns and sparkling new factories across the Baltic shore state.

“Renewable energy has become extremely valuable for our state,” said its premier, Erwin Selling, in an interview with Reuters. “It’s just a great opportunity — producing renewable energy and creating manufacturing jobs.

“From an industrial point of view we’d been one of Germany’s weaker areas. But the country is abandoning nuclear power. That will work only if there’s a corresponding — and substantial — increase in renewables. It’ll be one of Germany’s most important sectors in the future. We want to be up there leading the way.”

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Taiwan Does Solar In A Big Way – Asia in general understands the need to ditch coal

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China is having smog days in some cities that have pollutants 50 times higher then allowed in the United States. Rates that can cause lung damage in mere minutes. So everyone in Asia is well aware that they need to switch from carbon fuels to renewables. Unfortunately, India has not learned the lesson yet.  But Taiwan definitely has.

http://solarbusiness.com.au/rise-rise-taiwan-solar/?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+SolarBusinessServices+%28Solar+Business+Services%29

The rise and rise of Taiwan Solar

21 Oct, 2013

(I skipped the first couple of paragraphs)

Either way, this beautiful, mountainous, island nation has become a technological powerhouse in Asia. Driven initially by Japanese influences prior to World War 2, it has developed a highly successful semiconductor industry including wafer foundries, Integrated Circuit (IC) packaging and testing industries and was considered the world’s number one in 2011 in terms of IC revenues.

The Taiwanese semiconductor industry developed an early vertical integration model (upstream, midstream, and downstream sectors) including silicon materials and silicon wafering; midstream IC design, IC manufacturing, and IC packaging industries; and downstream computer, cellular phone, and consumable electrical product companies. The transition from semiconductor to photovoltaic industries was a therefore a logical and natural progression for Taiwan and explains why it has become so enormously important.

Fast forward to 2012 and the beginning of trade tariffs on Chinese made PV products in some countries.  With deep historical and business ties to China but technically an independent status, the importance of Taiwan’s PV manufacturing sector took a huge leap forward.

One example of the Taiwanese PV industries rise to PV success is WINAICO.  WINAICO’s parent company is Win Win Precise Material Co Ltd who established themselves in 2003 as a supplier and marketer to the semi-conductor industry. By 2007, it had created Winergy Solar and soon afterwards WINAICO, establishing a network of global sales offices and joint ventures to develop, market and deploy its PV technologies.

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