The March 22 CCOB Broomfield Community Forum to discuss the HAZID Report offered citizens and Broomfield City Council members a chance to ask probing and detailed questions to DNV-GL, the writers of the report, about the process, data collected, results, and other concerns. The panelists included Robin Pitblado, Cynthia Spitzenberger and Marisa Pierce from DNV-GL, as well as Barbara Ganong, a petroleum engineer, who worked on Broomfield’s behalf in the development of the HAZID. DNV-GL defines their purpose on their website as “to safeguard life, property, and the environment.” As the meeting unfolded, it quickly became clear that many citizens questioned the overall approach to this report and its value as a “risk analysis,” which is a requirement from the MOU with Extraction that needs to be fulfilled before Extraction can move forward with drilling.
DNV-GL opened the meeting by talking through several slides that detailed how they created the report. They described that they used ISO 17776, which is a methodology that takes a qualitative, holistic look at a situation and defines risk from there. This is not a quantitative analysis, they explained, which requires actual data input and careful data analysis. They explained that a quantitative analysis is only required when severe consequences or a high-risk situation has been identified. This industrial oil and gas development in our neighborhoods did not, in their analysis, pose a high enough risk to do a quantitative analysis. A white paper titled “Probabilistic Risk Assessment: Applications for the Oil and Gas Industry,” published by NASA and the Bureau of Safety and Environmental Enforcement, define the HAZID as “a structured brainstorming technique for the identification of all significant hazards associated with the particular activity under consideration. Usually conducted in the beginning of the project, it is the starting point to conducting qualitative assessment of major accident risks.” It’s clear that a HAZID is the starting point of risk analysis and often not the entire process. This article also identifies the following key point: “While effective at identification of the hazards, qualitative assessments do not quantify the probabilities of events, and therefore, make assigning any type of risk rating subjective and often difficult. Low probability, high consequence events are not defined as well as they might be with more quantitative methods.”
The complete HAZID can be found here, which details out the risks according to the findings of the workshop/ brainstorming session conducted by DNV-GL. Of particular note are what have been identified as “Serious risk scenarios,” all of which relate to vehicle incidents. There is one serious risk per phase of drilling.
The presenter focused heavily on the use of BMPs, or best management practices, to alleviate risk. This approach relies on strong operator management by Extraction on site and highly detailed enforcement by both the operator and the city.
Once the citizen question time opened, citizens asked questions ranging from financial concern to health and safety concerns to overall questioning of whether this is the right report for our current situation. In answering these questions, the presenters often referred to the “people in the room” and the “experience in the room,” which emphasizes that the HAZID is an extensive brainstorming session that relies solely on the experience and knowledge of the 15 people in this room to identify all risks.
One key takeaway for many residents was the breakdown of the group of “people in the room” for the HAZID brainstorming session/ workshop. It was clarified that there were 15 people in the room. Five were from Broomfield, five were from Extraction, and the other five were from DNV-GL. The DNV-GL representative explained that it is “completely normal” to include key stakeholders in these conversations and that “they couldn’t have done the study without them.” Several citizens are continuing to question the participation of Extraction in this process as they are direct benefactors of low risk assessments. For some, it feels like a direct conflict of interest.
Other key takeaways include:
When asked whether a medical professional or professionals were “in the room” at the HAZID workshop to evaluate the health and environmental impacts of this project, the DNV-GL representative explained that having doctors who don’t understand the technology in the room would make the process too hard as they would “have to stop to describe the terminology,” and it would take too long to include them. Many citizens over the course of the evening expressed their concern that health and safety were not at all a consideration, especially considering how many studies have come out and are consistently coming out linking industrial oil and gas activity to adverse health and environmental impacts. The DNV-GL representative expressed emphatically that while there is low level toxicity present in these kinds of operations, “it’s too hard to assess” the risk because the sources are so “low volume.” He later stated that if VOCs were causing cancer in large volumes, “we would be seeing this by now.” He continued that if health impacts had been proven to be “significant,” then they would have been considered. When further pressed by an audience member about the thousands of studies she has identified, he questioned the validity of her statement. He quantified “significant” as “more than single events surrounding a well site.” Upon a simple search for scholarly articles about the health implications of fracking, about 8,640 results are immediately available. At least 300 have been written in 2019 alone. Articles explore topics from the impacts from VOCs to the health of residents to the impacts on the environment and water. While not all of these articles focus on the clustering of impacts near oil and gas operations, several thousands of them do.
When asked repeatedly whether the “people in the room” at the HAZID brainstorming session/ workshop located and studied a twin well site containing this many well heads this close to such a densely populated area such as the Livingston pad, they identified that they knew of a well site this close to homes, but they did not mention whether there is any site the scale of the Livingston pad this close to neighborhoods that are this densely populated. It left open for argument that this development is unprecedented and therefore no twin site could be studied for comparison.
When questioned about how another event like the Extraction explosion in Windsor will be avoided amid homes and schools in our neighborhoods, the DNV-GL representatives explained that the Windsor site was studied in the brainstorming session using the experience of the people in the room. He stated outright that using best management practices will prevent this from happening in the future. When pressed further about which best management practices were used at Windsor and how they are improved upon in the new BMPs for this project, he was unable to answer. He explained that there were no BMPs in place at Windsor that he knew of. Residents pointed out later in the session that BMPs are subject to human error and that BMPs require careful oversight by both the operator and the City and State of Colorado to be effective. The DNV-GL representative responded that because the city has hired four new employees, all BMPs would likely be followed. Residents expressed their distrust in both Extraction and the City and County of Broomfield to enforce these regulations multiple times and in multiple comments.
Council Member Guyleen Castriota explained that Extraction was fined over $800,000 for a failure to monitor wellheads at one of their operations. She explained that Extraction “blew off testing the integrity of the wellheads” entirely, and insinuated that this was likely not an isolated incident in Extraction’s operations. The DNV-GL representative again emphasized the need for monitoring and oversight. The concern largely remained unanswered except for the reference to BMPs.
When asked if the Broomfield emergency management stakeholders signed off on this HAZID, it was explained that they did sign off and claimed that they were able to handle the risks identified here. Many were quick to note, however, that they did not think that the HAZID identified all risks, including large fires and explosions, and that those low probability, high consequence events were not accounted for either by the HAZID or the emergency responders. One community member commented that two firefighters have recently contacted her, explaining their doubts about Broomfield’s readiness for this project.
Council Member Kevin Kreeger expressed his concern that the sheer number of medium risks at 70, which could result in health risks to multiple people among other consequences, is too many to move forward with. He explained that this report is telling us that more than 10 people will be killed or suffer from irreparable injuries as a result of this project. He also expressed his disappointment in the pipeline risk analysis, which is incomplete and inadequate. The DNV-GL representative explained that loss of human life and risks are posed more to workers than community members. Council Member Kreeger expressed his request for a council member study session, “and this is not it,” he remarked. He closed his remarks by noting that he does not endorse moving forward on drilling for this project because of the inadequate documents and process failures identified.
The conversation concluded with several updates about city processes while many Broomfield and Adams County citizens continued to express their frustration in the lack of teeth in the enforcement process.