One of Many Reasons to Oppose Fracking in Illinois: Radioactive Contamination

Until now, Illinois has not been subjected to the oil and gas drilling practice known as “fracking” — hydraulic fracturing of the shale layer combined with multiple horizontal bores at each drill site. The main reasons for this have been economic more than political, as our previous Democratic governor and Democratic-controlled legislature rejected a bill for a moratorium on fracking a few years ago, and instead adopted a bill to “regulate” the practice.

Now, however, Kansas-based Woolsey Operating Company, LLC, has, for some reason, applied for a permit to frack in rural White County in Southern Illinois, about 60 miles from where I live. I have been opposing fracking for years, as a member of SAFE — Southern Illinoisans Against Fracturing our Environment, which fights for a complete ban on fracking and, ultimately, all fossil fuel extraction.

The reasons for opposing fracking are numerous, the most prominent being that it contributes to global climate chaos, a catastrophe already in progress. In addition, there are a number of well-documented local and regional extreme environmental hazards that are inherent in the practice — water contamination, loss of water resources, air pollution, noise pollution, increased earthquake danger (principally from waste disposal in injection wells), stresses to the infrastructure and negative impacts on public safety and quality of life.

There is also another danger that has received less attention, at least until recently: Radioactive contamination. The shale layer often includes radioactive elements, so dissolved particles of radium or undissolved particles of uranium or thorium may be in the formation water. During drilling, a mixture of oil, gas, frack water and formation water is pumped to the surface. The water is separated from the oil and gas into tanks or pits, where it is referred to as “produced water.” Thus, produced water may contain concentrated levels of radioactive materials. Produced water is usually re-injected into deep disposal wells or treated for reuse. Some dissolved radium settles out to form sludges that accumulate in tanks and pits, or form mineral scales inside pipes and drilling equipment. This poses a major threat to public and environmental health.

The following is my own public comment in opposition to Woolsey’s application. It speaks for itself. Other concerned Illinoisans may still submit comments opposing Woolsey’s applications, by e-mail, by July 28th, to DNR.HFPublicComments@illinois.gov. Please reference the application number in your comment, as I have done below. You will also find links to the application itself, and related documents, in the below comment.

Another option is to write up a comment and/or sign the Illinois Green Party’s petition, and join us in Springfield for a rally outside the Illinois Department of Natural Resources headquarters this Friday! See: https://www.facebook.com/events/1299938153461538/?acontext=%7B%22source%22%3A4%2C%22action_history%22%3A%22null%22%7D&source=4&action_history=null

PUBLIC COMMENTS FOR IDNR REVIEW NUMBER HVHHF #000001

TO: Illinois Department Of Natural Resources
 Attention: Oil and Gas Regulatory Staff
 One Natural Resources Way
 Springfield, IL 62702

The undersigned makes the following public comments concerning Woolsey Operating Company LLC’s application for a high-volume horizontal hydraulic fracturing permit in Illinois, including its supplemental documents. The application is more fully described as follows:

HVHHF #1, White County
IDNR Review Number HVHHF #000001
Applicant: Woolsey Operating Company, LLC, a Kansas limited liability corporation
Location: Between Springerton and Enfield, about 1.3 miles west of US Route 45;
 the site is bounded by County Road 1825 N on the north,
 County Road 50E on the west, and County Road 1725 N to the south
Information located online at: https://www.dnr.illinois.gov/OilandGas/Pages/PendingPermitApplications.aspx

My comments in this document are focused on grave concerns about deficiencies in two sections of Woolsey’s application, primarily section 25, on Radioactive Materials Management, and, where implicated, section 11, the Well Site Safety Plan. I note that, separately, I have endorsed and added my voice to comments that have been, or will shortly be, submitted by Southern Illinoisans Against Fracturing our Environment (SAFE), Food & Water Watch, the Illinois Green Party, the Sierra Club, Natural Resources Defense Council, and Illinois People’s Action.

The IDNR regulations at 62 Ill. Admin. Code § 245.210 (b)(7) require applicants to “submit a radioactive materials management strategy to test for and identify, manage, transport and dispose of any radioactive materials utilized or generated during the course of HVHFF operations.”

Woolsey’s application appears to be in compliance with the requirement to test for and identify radioactive materials — but nothing else. It therefore does not qualify as a “strategy” that meets the other requirements. This is especially alarming, and cannot be deemed adequate, in light of the fact that technologically enhanced naturally occurring radioactive materials (TENORM) brought to the surface and/or deposited on oil-field equipment in Southern Illinois is generally much more radioactive than in other regions nationally — and White County, in particular, has shown elevated radioactivity in oilfield equipment and soils more commonly than in the rest of Southern Illinois. (See USGS Fact Sheet, FS-142–99 — https://pubs.usgs.gov/fs/fs-0142-99/fs-0142-99.pdf , and James K. Otton, et al., Effects of produced water at some oilfield production sites in Southern Illinois, U.S.G.S. Open File Report 97–448, July 1997, pp. 6–7, 83 — https://pubs.er.usgs.gov/publication/ofr97448 )

Stating the deficiencies with greater particularity:

1. It does not identify what level of detected emissions in produced water, sludge, drilling mud, accumulated mineral scales on pipes and equipment, or in surrounding soil or surface water, will trigger removal or remedial action of any kind.

2. It does not identify — either in its Radioactive Materials Management Plan or its Site Safety & Health Plan — what level of workers’ exposure to radioactive emissions will trigger remedial action or what type of remedial action will be taken. It does not appear to include any requirement that workers at high risk of exposure will be provided with radiation-detection badges or similar devices that can provide reliable data on actual exposure.

3. The plan acknowledges that “radioactive materials might be removed from the site as wastes or within equipment as the equipment is moved from one site to another.” It states nothing about what precautions or methods will be used to transport radioactive wastes. It implies that radioactive wastes will simply be transported and disposed of in the Class II injection wells described in the Hydraulic Fracturing Fluids and Flowback Plan irrespective of the level or type of radioactive emissions detected. It clearly does not describe any alternative plan or contingency for the disposal of wastes above any given threshold of radioactive emissions.

4. The plan states that “[p]rior to disposal or recycling, materials that are suspected of containing NORM materials will be subjected to field testing and/or laboratory analysis to assess the possible requirement to be managed as radioactive wastes. If warranted, the appropriate NRC and DOT requirements shall be followed.” Using passive voice, it does not state who shall determine what “materials” will qualify as “suspected,” or what criteria shall be used to determine when materials are “suspected” of containing NORM or TENORM materials. It does not cite any specific NRC or DOT requirements. Neither the Atomic Energy Act of 1954 nor the Low-Level Radioactive Waste Policy Act cover NORM. The Nuclear Regulatory Commission has no authority over radioactive oil and gas waste. (Brown, Valerie J., Radionuclides in Fracking Wastewater: Managing a Toxic Blend; Environ. Health Perspect., Feb. 2014; DOI: 10.1289/ehp.122-A50 — https://ehp.niehs.nih.gov/122-a50/ ) Thus, at least without citations, the assurance that “appropriate” NRC requirements shall be followed, would appear to be meaningless.

In sum, neither the Radioactive Materials Management Plan nor the Site Safety & Health Plan provides any specific details regarding how radioactive materials above normal background levels — or above any level — will be managed, transported or disposed of any differently than any other materials. The application cannot possibly be deemed to be in compliance with § 245.210 (b)(7) and the public has no basis for concluding that public and environmental health will be adequately safeguarded if this permit is approved. Considering the disastrous consequences that have befallen the state of North Dakota, for example, as a consequence of poor regulation of radioactive wastewater, it would be unconscionable to grant a permit to Woolsey based on this application. (See, e.g., https://www.desmogblog.com/2016/05/08/duke-university-study-finds-legacy-radioactivity-water-and-soil-contaminated-thousands-fracking-wastewater-spills.)

The undersigned urges you to uphold your duty to protect Illinois’ natural resources and our public health and safety, by denying Woolsey Operating Company LLC’s well permit application (HVHHF-000001).

Thank you for your consideration.

Sincerely,

Richard J. Whitney

[Address Information Withheld]

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