August 28 Council Meeting Brings Concerns about CDP Risk Analysis, Air Quality Monitoring and Limits on Future Citizen Comments

The August 28 Council Meeting marked the first meeting following the August 20 conditional approval of the CDP by City Manager Ozaki, with no update since August 20 on any talks with Extraction on their acceptance of the conditions.  Anticipating public comments on the CDP, Mayor Ahrens prefaced August 28 Citizen Comments by stating that they would hold public comments to one hour from now on since “some of our decisions made after 11 or 12 many not be so good.”  On this night, objections to the conditional approval of the CDP were stated by eight residents, including an in-depth Citizen’s Risk Analysis presented by Pat Talbot and Laurie Anderson.  At about 11 pm, Council entered Executive Session to seek legal advice on both the CDP and the Broomfield Way lawsuit.

During the public meeting, Item 11m Resolution No. 2018-150 was passed unanimously by Council to authorize the agreement with Ajax Analytics for the Air Quality Monitoring Plan related to the 84 well Extraction development.  At the beginning of the meeting, Council Member Law-Evans asked for this item to be placed on the Consent Agenda which would not have allowed for discussion.  Council Member Kreeger objected, so the item stayed on the Council Business Agenda at which time Council Members Shaff, Kreeger and Beacom and resident Jean Lim commented.

IMPORTANCE OF RISK ANALYSIS IN CDP

Pat Talbot began Citizen Comments by presenting the Citizen’s Risk Analysis with co-author Laurie Anderson.  (Please see original document here. Updated risk table can be found here.)  Pat stated that benefits of their risk analysis included a numerical impact scale, calculations based on documented references, the quantification of SEC risks, and the analysis of Best Management Practices (BMPs) which can mitigate risk.  As supported by a table on page 16 following pages of calculations, the document stated that, “The result of this risk analysis is that while individual risks for a single well are near negligible, the cumulative risk for the proposed 84 wells is substantial. Best Management Practices, as stated, are deemed to be largely ineffective in reducing risk.” The risks listed in the table include the following:

  • Cement/casing, leak
  • Spills
  • Blowout, Fire, Explosion
  • Pipeline explosion, leak
  • Benzene, air pollution
  • Traffic on roads
  • Traffic Fatality Increase
  • Traffic Injury Increase
  • Noise pollution
  • Odor
  • Light pollution
  • Stress
  • Real Estate Loss
  • Municipal Tax Loss
  • Serious worker injury
  • Worker fatality
  • Pipeline Death
  • Pipeline Injury
  • Earthquake
  • Wildfire
  • Flood
  • Tornado
  • SEC financial risk
  • SEC drilling risk
  • SEC resources risk
  • SEC laws risk
  • Natural Disasters

Since the August 28 presentation of the preliminary Citizen’s Risk Analysis, additional risks have been identified including:

  • Drinking Water Supply
  • Emissions During Maintenance
  • Frac Hits
  • Crime Rates/Sabotage
  • Radioactivity
  • Silica Sand
  • Strain on Local Government Resources

Laurie Anderson emphasized that enforcement measures were critical.  She stated, “Until you have the risk analysis complete, until you know what all the mitigation methods are, and which ones will be enforced, what the City is going to enforce in its contract, what the COGCC is actually going to enforce, it [risk analysis] is such a critical component.”  Laurie cited the example of the August 24 emission of a plume of black smoke on Extraction’s Coyote Pad as an example of the need for enforcement.  Since the COGCC determined there was no violation of the rules since emissions occurred during maintenance operations, Laurie wondered how often Extraction would claim to be doing maintenance operations in Broomfield to avoid being cited for violations.

Both Pat Talbot and Laurie Anderson volunteered do a longer presentation to Council and Staff, along with offering their time to assist the City in hiring a third party risk analysis provider.  Pat and Laurie were clear that any complete risk analysis had to be both quantitative and qualitative.  Pat stated that their goal was to keep refining their Citizen’s Risk Analysis in order to eventually publish it in a professional journal.

AIR QUALITY MONITORING

Council also passed a resolution to authorize the agreement with Ajax Analytics and CSU for their Air Quality Monitoring Plan related to the 84 well Extraction development.  The joint proposal of Ajax Analytics and CSU was first reviewed by Council at the July 17 Study Session after a committee of staff, consultants and residents evaluated eight proposals.  The agreement will cost Broomfield $1,179,775 for air quality testing, with 2018 costs of $715,955 and 2019 costs of $463,820.  A balance in the County General Fund from previous oil and gas revenues will pay for the costs.  Extraction is only required by the Operator Agreement to provide $20,000 annually for air quality monitoring costs.

The platform monitoring stations will be located at the Extraction well sites, in neighborhoods and at schools.  Please see the location map hereIn addition to the internet connected sensors and whole canister sampling at the platform monitoring stations, there will be a mobile plume tracking vehicle to process plume dispersion data.  In response to a question raised previously in the July 17 Study Session, Ajax CEO Brent Buck said that they are exploring better batteries for their sensors in order report sensor data more frequently than every hour.  Canister collection will be continuous and will be sent for analysis weekly and reportedly quarterly.

The data collected will be used by the City to notify citizens of alerts and emergencies.  Council Member Kreeger asked what levels of VOCs will be used as a threshold to alert citizens to conditions threatening their health and safety.  City Assistant Public Health Director Laura Davis explained that shifts would be detected more than absolute levels.  Dr. Jeff Collette, head of the Atmospheric Science Department at CSU, stated that new CDPHE levels would be used when shortly completed, an effort with which CSU has been involved.

There will also be a web portal available to the public.  Resident Jean Lim was concerned that the document did not give much detail about the public portal that would be available, as it stated only that additional features would be added at the “option” of Ajax with direction from the Broomfield Staff.  She stated that residents have a basic distrust of Extraction and that Staff could anticipate that there would be public interest in monitoring the data.  Council Member Shaff in his comments also stated that a goal should be for the public to have full access to data.

The next Council meeting will be held on Tuesday, Sept. 11 and is expected to include the second reading of three amendments to the regulations.