First Presentation of “Risk Assessment:” “Death by One Thousand Cuts”

At the February 19, 2019 City Council Study Session, citizens, council and staff heard DNV-GL present their highly anticipated and controversial “risk assessment” report for the 84 well Extraction Project in Broomfield that is already under construction.  DNV-GL, a Norwegian owned company with offices in Katy, Texas, purports to “enable organizations to advance the safety and sustainability of their business” and “works in collaboration with their customers to run joint industry projects to develop new solutions, standards and recommended practices that add value by solving industry challenges.”

In Broomfield resident Pat Talbot’s February 18 email to City Council after he reviewed the report, he stated that, “Narrowly defined hazard scenarios (412) mask the risk of either one or another risk occurring. This ‘death by one thousand cuts’ portrays 412 risks that are individually low rather than a few dozen risks that are high. Death by a thousand cuts (psychology), the way a major negative change which happens slowly in many unnoticed increments is not perceived as objectionable.” According to Broomfield resident Laurie Anderson’s review of the report, “There are several potential ‘hazards’ that were not considered and we will be providing a more detailed list to the City. It should be noted that the HAZID, or Hazard Identification, results are only as good as the inputs.”

DNV-GL was contracted by the City and County of Broomfield to perform a HAZID, or Hazard Identification.  According to many citizens and neighborhood groups, the HAZID is not sufficient as “the risk analysis has been a requirement since the final negotiations with Extraction and remains a requirement still today.”  Extraction was expected to provide a risk analysis as part of the Comprehensive Drilling Plan (CDP).  During the lead up to approval of the CDP by the City, it was determined that Extraction used a risk analysis which was not their own but one provided to them by Charles Taylor Company.  Extraction withdrew the Charles Taylor risk matrix from the final version of the CDP.  The City approved the CDP without the risk analysis and then hired DNL-GV to do a HAZID.  You can read Broomfield resident Laurie Anderson’s analysis titled “Project and Pipeline Risk Requirements Based on the Operator Agreement and Associated Comprehensive Drilling Plan” here. 

To do their analysis, DNV-GL chose to use data from oil and gas fields in New Mexico because it is “in the region.”  Mayor Ahrens pointed out that the Denver-Julesburg Basin has different characteristics, and the presenter agreed that there are overthrust issues here which can cause earthquakes.  It is not clear why DNV-GL did not use Colorado data from the Colorado Oil and Gas Conservation Commission and Colorado Department of Public Health and Environment websites.

The three DNV-GL presenters were Senior Consultant Marissa Pearce, Consultant Cynthia Spetzenbeurger and Upstream Oil and Gas Consultant John Sturgeon.  This Texas group, along with Broomfield City staff, North Metro Fire and Rescue Department and eight Extraction representatives, performed a HAZID study during a two-day long workshop.  Broomfield resident Laurie Anderson stated after the Study Session, “It is unfortunate that the City did not consider impacted residents as a crucial part of this process and give us a seat at the table, nor did they involve the Council Members in this process.”

Senior Consultant Marissa Pierce said that DNV-GL identified a variety of risks including:

High risks- 0

Serious risks-5

Medium risks- 71

Low risks- 336

DNV-GL identified three major medium risk categories:

  1. Well Blowouts. DNV-GL maintains that the best Best Management Practices (BMPs) to prevent blowouts are a “blow-out preventer and drilling mud.”
  1. Airplane collisions. Prevention BMPs include lighting, flight plans and emergency response plans.
  1. Loss of power at the drilling site. One prevention BMP would be using a secondary power source.

The largest risk concern mentioned was that of TRAFFIC ACCIDENTS involving oil and gas vehicles and residents’ privately owned vehicles.  It is unknown at this time how these risks will be mitigated in Broomfield.  Traffic safeguards include addressing access routes, traffic volume, flow and time limitations.

The presentation employed a “Bow-Tie” Diagram to show Causes and Consequences for each type of hazard and event.  The possibility of oil droplets igniting as a hazard was brought up several times as infrequently mentioned in these types of HAZID discussions.

After the presentation, Council Members were able to ask limited questions.  Council Member Sharon Tessier suggested that another meeting should be scheduled to delve deeper into the DNV-GL report.  It was also suggested by other council members that citizens should have time to ask questions and make comments. The type of format for this future meeting was not determined.

After the DNV-GL report was made public on February 15, Broomfield residents Pat Talbot and Laurie Anderson quickly reviewed its 507 pages for errors, omissions and what may not apply to the Broomfield project.  In response to a February 18 request from Pat Talbot to Council to be allowed to present his review for five minutes, Mayor Ahrens replied, “I don’t really want to set that precedant [sic], our meetings are long enough already…Furthermore, we will likely have a public meeting on this very item and that would be a more appropriate time for public comment.”

The long list of immediate concerns raised by Pat Talbot and Laurie Anderson included:

-DNV-GL did not evaluate each site separately.

-The Livingston site was mentioned only once.

-Broomfield was not mentioned after page 29 of the 470 page report.

-HAZID is a scenario-based approach, which means they did not look at risks on a cumulative basis.

-They did not look at refracks and/or recompletions.

-They felt that one pad is representative of all pads.

-They did not consider impacts on nearby populations, saying that Colorado has much stronger regulations than Texas.

-They did not consider loss of property values.

-They did not consider ambulance delays.

– Toxic air, liquid, and solids were identified risks, but health consequences were not discussed.

The City Staff has stated that Extraction would be providing their required pipeline analysis in February, after much of the pipeline has already been installed.  Drilling is scheduled to begin on the Interchange B Pad in late March.

Stay tuned for follow-up meetings after Broomfield’s City Council has more time to read the report and formulate their questions. DNV-GL will be back to provide answers.  According to indications at the Study Session, citizens will be allowed to make comments and ask questions.

written by: Becky McLeod