Dear Representatives: Fracking is Unsafe

Bill Rau, local environmentalist and Illinois People’s Action activist, sent the following letter on April 17th to Illinois state legislators, explaining the unsafe fracking practices codified in House Bill 2615 (HB2615). With his permission, I’ve printed the letter in its entirety in this post, with embedded videos and photos.

Dear Representatives:

On March 29th, I wrote you on limitations in the definition of hydrofracking in HB2615 and promised to follow with a letter on the unsafe practices codified in the bill. Here, I offer a brief elaboration on how HB2615 sanctions water, air, and soil pollution.

1. Water.

The setback in HB2615 for private water wells is 500 feet from gas and oil wells; the setback from streams, rivers, lakes, and reservoirs is only 300 feet. Figure 3 in Osborn et al.’s article in the Proceedings of the National Academy of Sciences (figure shown below) shows why these setbacks are unsafe for shale gas. Osborn’s findings establish a very high probability of dangerous levels of methane contamination in private water wells when fracking occurs within 3,280 feet (1,000 meters) of a well. At levels of 10 milligrams of methane per liter of water (the beginning of the grey band in Figure 3) occupants in a home with contaminated water wells face the risk of fire, explosion, or asphyxiation.

Figure 3. Methane concentrations as function of distance to nearest gas well

The private well setback in HB 2615 is less than 1/6th of the minimally safe distance. Since well pads can be placed very close to the shoreline of a reservoir (300 foot shoreline setback; 1,500 foot setback from intake pipe), with horizontal legs of shale gas wells allowed to run directly underneath the reservoir, city water supplies receive little protection from pollution.

2. Air.

Volatile organic compounds, aromatic hydrocarbons, other air pollutants, and raw methane are released during well drilling and completion, production, processing and transmission of gas and oil. These emissions are not visible to the naked eye but can be seen with an infrared camera. This short video, “The Intersection of Between Hydraulic Fracturing and Climate Change” prepared by Dr. Anthony Ingraffea (Cornell University), a leading expert on fracture mechanics, shows what these emissions look like with an infrared camera.

Methane Emissions from Fracking – Dr. Ingraffea

Emissions given off by produced water and oil battery tanks, flares, and most especially condensate tanks, can also be considerable, as the next short video will show. Please note the pollution and black carbon emissions from flares because flares will dot the Illinois landscape, if industrial scale hydrofracking is allowed in our state.

The cumulative effect of flares surrounding Williston, North Dakota – representing less than 1/5th of the total Bakken field – is now so extensive that the area lit up at night is about as large as the bright urban lighting of the Chicago metropolitan area. The part of the Bakken field developed thus far is circled in the photo below.

Source: NPR, A Mysterious Source of Light Shows Up in the North Dakota Dark, by Robert Krulwich (January 16, 2013)

Do we want large swaths of Western, Central, and Southern Illinois so lit up, an outcome that would leave, not only rural areas, but large parts our more densely-populated state under a plume of toxic gases? Has anyone examined the body of research on the adverse health effects of living next to the roar, stench, and noxious emissions of oil- or gas-field flares?

What I find particularly worrying is the provision allowing for gas and oil well development practically next door to a school (500 foot setback from the property line). Emissions from industrial-scale shale gas activities in Texas and Colorado have created dangerous amounts of ground-level smog. Dr. Theo Colborn bluntly warns that smog “slowly eats away at the tissue of the lungs…The lungs cannot replace these damaged cells” (Video of Dr. Colborn; Dr. Colborn Article). Furthermore, these emissions can drift miles downwind from the sites of drilling, fracking, well completions, hydrocarbon processing, flares, and storage tanks.

Fossil-fueled air pollution is now so severe in Asia that 1.2 million Chinese died prematurely from air pollution in 2010. School children in Beijing often have to forgo exercise or exercise inside their schools because it is unsafe to play outside. Outside activities and sporting events are cancelled when pollution is too high. Upscale, private schools in China now build purified air domes so that students can practice sports without damaging their lungs.

Will Illinois school children, located in a frack zone, be prohibited from exercising in their school playgrounds in the future because it will be unsafe to do so?

3. Soil.

One of the largest operational costs for oil or gas wells involves the storage, transport, and disposal of produced water — the waste water emerging with gas or oil after production begins. This water is then stored in tanks until reused or trucked to a disposal site. More properly called brine, it has tree-killing levels of salt, contains toxic elements, such as barium, manganese, vanadium, lead, and arsenic, and may contain highly elevated levels of radium-226, which has a half-life of 1,600 years.

Some truckers dump this toxic brine into rivers and other areas in the countryside, or leave the valves open on their trucks, as this photo shows.

Source: Wetzel County Action Group

Due to the lack of enforcement efforts, this cost-cutting practice appears to be growing, especially in North Dakota. According to Jeff Keller, Army Corps of Engineers, “There is no enforcement…None.”

Citizens are documenting dumping, apparently to no avail, because state agencies are turning a blind eye to the practice:

Without a comprehensive and strictly enforced system of trucking manifests, equivalent to what is required for transporting low-level radioactive waste, it will be impossible to stop dumping in Illinois. And there is no such system for manifests included in HB2615. Such dumping, or the use of produced water as a dust control agent or de-icer, will create a gradual but eventually dangerous buildup of soil-sterilizing salt, toxic elements, and radioactive materials in our environment.

Here, then, are three critical areas where HB2615 falls woefully short. We therefore have great difficulty understanding the support in Springfield for this legislation. We are told that “regulations are needed,” but does not the brief review above show these industrial practices to be inherently unsafe?

Illinois citizens have a constitutional guarantee to a healthful environment in Article XI, Section 2 of our State Constitution:
Each person has the right to a healthful environment. Each person may enforce this right against any party, governmental or private, through appropriate legal proceedings subject to reasonable limitation and regulation as the General Assembly may provide by law.

Would not HB2615 compromise citizens’ constitution right to sue the oil and gas industry for pollution of our air, water, and soil? Would not HB2615 end up protecting the industry by undermining citizens’ rights to enforce thorough legal proceedings their constitutional right to a “healthful environment?”

Sincerely yours,

William C. Rau
Spokesman, Illinois People’s Action &
Professor Emeritus, Industrial Sociology
Illinois State University