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We Have What the Industry Says Does Not Exist

Mailed Tuesday, November 20, 2012

To:

The Honorable Governor Quinn Lt. Governor Sheila Simon Marc Ayers, Lt. Governor’s Office Speaker of the Illinois House of Representatives Michael Madigan Mary Morrisey, Political Director, Office of the Attorney General Lisa Bonnett, Director Environmental Protection Agency Marcia Willhite, Director Water Bureau, IL Environmental Protection Agency Maggie Carson, Communication Manager, IL Environmental Protection Agency Raghav Murali, Legislative Liaison, IL Environmental Protection Agency LeMar Hasbrouck, Director, Illinois Department of Public Health Representatives David Reis, Brandon Phelps, Mike Bost, John Cavaletto, Jerry Costello II, Gary Forb, John Bradley President of the Senate John J. Cullerton Senator David Luechtefeld

You are holding in your hands an IEPA publication the oil and gas industry says does not exist.

Our organization–SAFE (Southern Illinoisans Against Fracturing Our Environment)– educates the public and public officials of the dangers of high-volume horizontal fracturing, or fracking.

The oil and gas industry is spending millions in an advertising campaign to mislead the public about the “safety” of fracking. One of these claims is that this technology has been used since the early 1940’s and there have been no “documented” cases of the contamination of groundwater, or no “confirmed” cases of contamination. This claim is false for Illinois.

The Illinois Environmental Protection Agency has documented, in the enclosed 128 page Illinois Oil Field Brine Disposal Assessment staff report, that the industry’s operations in Illinois, using traditional vertical hydraulic fracturing, has contaminated ground water, caused illness and death to livestock and devalued property values. Note first that when the industry today boasts of a safe track record for fracking, they are referring to conventional fracking, i.e., vertical drilling only: straight down and fracturing shale formations around the well bore. This conventional method has been used in Illinois since the 1940’s but differs dramatically from the newer fracking technology known as high-volume horizontal fracking. In the newer method, the drilling first goes down vertically and then turns sideways and goes horizontal. Compared to vertical fracking, horizontal fracking requires exponentially more fresh water and sand, and chemicals to keep bacteria from building up during high temperatures of drilling. Staggering quantities of fresh water are mixed with toxic chemicals, and after injection, the used water has become a highly toxic waste fluid that cannot be returned to the hydrological cycle. Currently, there is no safe disposal method for this highly toxic waste fluid, so the industry has been burying it in deep injection wells underground, which poses further risks for ground water contamination.

The enclosed report details how the industry has attempted to dispose of this highly toxic waste fluid over the course of the past 60 years, from dumping it into streams and rivers to the unsuccessful use of evaporation pits. This report focuses on contamination from the disposal of fracking waste fluid, which the industry terms “brine,” in Illinois over the course of several years.

Enclosed please find a copy of the 1978 Illinois Environmental Protection Agency report entitled “ILLINOIS OIL FIELD BRINE DISPOSAL ASSESSMENT.”

This report includes the following statements:

“The highly saline waters associated with oil production pose a threat to water and land. The daily disposal of approximately 973,000 barrels of brine in Illinois has been responsible for the sterilization of thousands of acres of productive land, 3,000 recorded acres in White County alone (Fasig, personal communication). Reports from individuals indicate that oil field brine has also been responsible for the sickness or loss of numerous animals.”  Report at 11.

“In addition to raising the concentrations of many chemical constituents of local ground water far above the maximum contaminant levels set by the IPCB, many of the brine holding ponds in central and southern Illinois are responsible for vegetation kills covering a limited area generally of a few acres or less. These vegetative kills are discernable from the ground and from aerial photographs, as can be seen in Plates 1 through 5 of the four study sites ***.”  Report at 14.

“Brine-polluted ground water may eventually infiltrate public or private water supplies, or percolate to the surface. Water supplies for farms and dairy operations can become saline, leaving cattle and a family without potable water. This was the case for a Clinton County dairy farmer and his family in 1976, when highly mineralized waters infiltrated his local ground water supply (Case I – Appendix B).

Productive farm land can be left completely unvegetated as can be seen at a site in south central Bond County. In this case a field adjacent to a brine pit was left void of vegetation after saline ground water percolated to the surface (Case II, Appendix B).

Property values can drop as a result of threatened ground water contamination. This occurred in 1977 at a housing development located near a brine pit in Rochester, Illinois, after elevated chloride concentrations were found in the surrounding ground water (Case III, Appendix B). These are just a few examples of environmental degradation through brine pollution that have occurred in Illinois over recent years.” Report at 14.

“However, even though these cases have occurred in close proximity to active oil field brine disposal operations, lack of acceptable legal evidence has left land owners without means to secure compensation for damages incurred.

One of the important characteristics of brine pollution often overlooked until the damage has been done, is that the pollution cannot be readily reversed by merely eliminating the existing source. Inground water, brine pollution may persist for decades and travel several miles from its point of origin before it is appreciably diluted.”  Report at 20.

“In old production areas, abandoned wells may pose a serious threat to groundwater quality. Unplugged and improperly plugged wells as well as other pathways (fault lines, old coal mines, karst fractures) provide possible vertical communication between saline and fresh water aquifers. An increase in formation pressure due to secondary recovery operations can supply the hydraulic pressure required to transfer the saline fluids from depth to an elevation adjacent to a fresh water aquifer, via an abandoned casing (Figure 14). Once this situation is established, the corrosion process and the failure of the casing are hastened.

During the relatively limited field reconnaissance, a few unplugged, uncapped and improperly plugged wells were noted. In addition to these, the records of the Illinois Department of Mines and Minerals indicate that there are thousands of plugged wells within the state. Many of these wells were plugged prior to the 1940’s before plugging records and specifications were developed, and may not have retained the integrity necessary to restrict vertical migration of highly saline waters. Ultimately, the migration of saline waters through these casings could lead to the degradation of otherwise potable ground water resources.”  Report at 44.

CONCLUSION

Regarding the multitude of unplugged, uncapped, or improperly plugged wells, SAFE notes that the problem will be exacerbated by the State’s current lack of resources to monitor the huge amounts of fluids that would be needed for the newer method.1

SAFE is aware of much evidence that the current methods of high-volume horizontal hydraulic fracturing not only are too dangerous for use today but also present unacceptable risks of adverse environmental, health, and safety risks in the future. The 1978 Report presents evidence that hydraulic fracturing as used in the 1970s and before had adverse consequences.

The U.S. EPA recently announced that follow-up tests have confirmed its December 2011 test results that fracking in Pavillion, Wyoming, has contaminated drinking water.2

By way of explanation, we note that one of the conclusions in a Duke University study published July 19, 2012, in the Proceedings of the National Academy of Sciences was that in Pennsylvania fracking areas, naturally occurring pathways can allow chemicals and contaminated fracking water to migrate into the drinking water supply.3

This evidence debunks the industry claim that “fracking” has been performed since the 1940s without a problem. With unplugged and improperly plugged wells throughout Southern Illinois, high-volume horizontal hydraulic fracturing would be a serious danger to the health and safety of Southern Illinois residents.

For additional evidence, please see SAFE’s website:  www.dontfractureillinois.net

In light of the evidence of the dangers of fracking in Illinois, even in its most benign state, we urge you to support a two year moratorium on horizontal hydraulic fracturing until the environmental and public health issues can be addressed. Experience in other states demonstrates conclusively that horizontal hydraulic fracturing will take a much greater toll on the health and well being of citizens and the environment in Southern Illinois than the more primitive vertical hydraulic fracking. 

Sincerely,

Lynn Waters

Vito Mastrangelo

Charles Paprocki

Barbara McKasson

SAFE

Footnotes:

1   “The DNR had 1,800 employees and a budget of about $100 million in 2002. Now that’s down to about 1,200 people and $45 million. Cuts have come every year as lawmakers and a string of governors — from George Ryan to Pat Quinn — signed off on state budgets that gave the department less and less as state revenue dwindled.”  http://www.dailyregister.com/article/20120824/NEWS/120829369  (last visited 10/22/12)

2   http://www.businessweek.com/news/2012-10-10/epa-says-test-of-wyoming-water-consistent-with-prior-results  (last visited 10/22/12)

3   http://www.post-gazette.com/stories/business/news/findings-are-mixed-in-fracking-water-study-644003/  (last visited 10/22/12)

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