By: Najmedin Meshkati, Nima Jabbari, Jamie Heinecke, and Cyrus Ashayeri
As we all know, on November 4 there will be a referendum on a fracking ban in Denton, TX. Regardless of the outcome, the impact of this unprecedented grassroots movement will transcend well beyond Denton's city limits and affect the future of the entire oil and gas fracking industry in the US. We believe that the society's decision of using more fossil fuel in the future and, consequently, to frack or not to frack, is a major public policy issue which is beyond the scope of our technical analysis. Nevertheless, as engineers and safety advocates, we strive to ensure that if there is fracking in the US, then it must be done in the safest and most environmentally conscious manner, using a proactive systems-oriented approach with strong safety culture.
The main concern at Denton has been the safety and environmental impacts of fracking for its community. As one of "Dentonites," "fracktivist" Candice Bernd, has stated in her recent essay, "[t]he push for a ban comes primarily in the context of the group having tried everything else. It is the next logical step for our community to seek protection from the gas industry."
However, this is not the first time that a group of decent citizens in the US are fed up with the safety and environmental record of an energy industry operation in their backyard and frustrated with the federal or local governmental/administrative bodies entrusted with its oversight. Typically, concerned citizens try to exercise some direct level of control by resorting to lawsuits, sometimes under archaic provisions of a nuisance law, and referendum mechanisms to curtail or stop such operation.
On March 6, 1990, Torrance residents in Southern California considered a ballot measure that could have forced the Mobil Oil Co. to spend up to $100 million to restructure its refinery operations and eliminate the use of hydrofluoric acid, a highly toxic chemical that was used to boost the octane level of gasoline. The vote was a response to several mishaps at the refinery in prior years. Similar to the situation in Denton, the cavalier attitude of the industry toward the refinery safety and their inaction regarding safety improvements, of course, aggravated the situation and fueled the public's anger. [For further information, Please refer to Meshkati's Op-Ed in the Los Angeles Times, March 1, 1990, "Can Voters Head Off Refinery Calamities?"]
There is no question that fracking has drastically helped the US economy. In fact, it is primarily due to fracking in the U.S. that already, according to a recent article in the Wall Street Journal, "since March 2008, oil production has increased 58% and natural-gas output has risen 21%, making the U.S. the world's largest producer of both fuels, according to federal and international agency statistics;" and "jobs directly related to oil and gas production have nearly doubled in the past 10 years to 697,000, government data shows." Additionally, from the Wall Street Journal:
Last year, a group from Yale estimated that shale gas production contributes over $100 billion to U.S. consumers annually. Jobs have been created, many landowners have benefited financially, and lower gas prices have provided relief for consumers in the form of lower heat and electricity bills.
Nevertheless, the Dentonites' agony should be considered as a rude-awakening for everybody in the US; the fracking industry, federal regulatory agencies, and local oversight bodies. All parties should note that the time and practice of "business as usual" is over, and they should address safety, health and environmental issues of fracking in a proactive and transparent manner.
We have extensively studied the role of human factors and safety culture in the fracking operations and have recently published a research article on these issues. It is an undeniable fact now and we know that major man-made accidents, which are often characterized as 'low probability, high consequence events', are mostly caused by a multitude of factors that compromise barriers to the loss of control or breach defenses for safe functioning of intended systems. It is now known that both the performance and the inherent accident potential of complex human-technological systems, such as fracking operations, are functions of the way their parts -- engineered and human -- fit together and interact. Research has shown that on many occasions, the error and "negligence" and the resultant failures are both the attribute and the effect of a multitude of factors.
On many occasions, "human error" is caused by inadequate workers' response to unfamiliar events. These responses depend very much on the conditioning that takes place during normal work activities; workers' behavior is conditioned by the conscious decisions made by work planners or managers. These include: poor workstation and workplace designs, unbalanced workload, complicated operational processes, unsafe conditions, faulty maintenance, disproportionate attention to production, ineffective training, non-responsive managerial systems, poor planning, lax oversight and inadequate enforcement of safety regulations, and an overall weak organizational safety culture.
The safety culture goes beyond specific rules and rote adherence to standard operating procedures in any organization. In other words, creating safety culture means instilling attitudes and practices in individuals and organizations that ensure safety concerns are proactively addressed and treated as high priority. An organization fostering strong safety culture encourages employees to cultivate a questioning attitude, a prudent approach to all aspects of their jobs, and creates open communication between line workers and management.
However, not always mentioned is that a good majority of these "errors" or "negligence" were in fact system-induced. According to several studies, including our own, it should be remembered throughout the investigation that error should be considered as a consequence and not necessarily a cause. As the world-renowned scholar, Professor James Reason of Manchester University stated, which could characterize many technological systems' accidents, such as fracking accidents, "rather than being the main instigators of an accident, operators tend to be the inheritors of system defect created by poor design, incorrect installation, faulty maintenance and bad management decisions. Their part is usually that of adding the final garnish to a lethal brew whose ingredients have already been long in the cooking." As such, it is a gross oversimplification to attribute accidents to the actions of front-line workers or negligence of their immediate supervisors, prior to investigating all the contributing root-causes to the system's failure.
We must consider the human factors issues involved in each stage of the process. By examining each stage of hydraulic fracturing, the specific human factors issues involved in the overall process can be addressed and ultimately both the safety and the efficiency of the entire system can be improved.
For instance, both fracking industry and their cognizant safety oversight agencies should develop a thorough and comprehensive incident/accident reporting and investigation system to systematically address all the root-causes by concentrating on modern human-systems integration methodologies, to disseminate lessons learned, and to avoid the next one. We tried to analyze the EagleRidge Operating, LLC's Smith-Yorlum 7H gas well blowout at approximately 1:30 a.m. on April 19, 2013, which was reported to City of Denton nine hours later at approximately 10:45 a.m. We examined the only two terse available reports concerning this major accident, which released chemicals and at least 100MCF of natural gas to the environment: The one page Incident Report filed with the Railroad Commission of Texas (RCT), as well as the brief write-up posted on the Emission Event Reporting Database, of the Texas Commission on Environmental Quality (TCEQ). And we found them to be woefully incomplete and inadequate, as far as root-cause analysis and lesson learned are concerned.
Another related example deals with exceeding injection pressure limits as a violation that according to the EPA has been repeated 1,100 times from 2008 to 2012 in EPA Class II injection wells. Although, in this context, this phenomenon has an objective of not fracturing the formation and is different from the injection in the hydraulic fracturing operation, it still can have serious application in regulating the safety and environmental requirements to be complied within hydraulic fracturing. More importantly, it is of high importance to pay attention to the role of human factors in pressure-monitoring systems in fracking, because compared with waste injection, the pressure being implemented in the fracturing process is quite higher and it requires stringent monitoring precautions when working onsite.
Unfortunately, just like the Torrance vote in 1990 -- whatever the result will be in Denton on November 4, 2014, it will not fix anything in the long run in the US. Even if approved, the frackers will only move out from Denton into other areas. Many more Denton Déjà vu in the future. An acceptable solution can only come from the recognition by the fracking industry that it must operate with a diligent conscience for safety, environmental and social concerns, and a realization by Denton residents that this industry's presence benefits the economy and possibly the country. The problem cannot be solved by referendum, legislation or litigation. It can be solved by a genuine and honest soul-searching by the oil and gas fracking industry about their past practices and a partnership with and its neighbors based on a candid exchange of views and information between the partners.
Finally, the fracking industry must listen to Dentonites' cry for help and their numerous other cohorts around the country, to heed their call for serious change, and to initiate a genuine paradigm shift when it comes to their safety and environmental responsibilities by developing proactive, scientific and systems-oriented approached based on human factors and safety culture considerations.
_________________
Najmedin Meshkati, Nima Jabbari, Jamie Heinecke, and Cyrus Ashayeri are, respectively, a professor and students at the Viterbi School of Engineering, University of Southern California (USC). For the past 30 years, Prof. Meshkati has been teaching and conducting research on risk reduction and reliability enhancement of complex technological systems; recently he has been on two national panels in the United States investigating two major accidents; the Deepwater Horizon Explosion and the Fukushima Nuclear Accident. Students are members of Prof. Meshkati's multidisciplinary USC Fracking Safety Study Group, an independent academic effort with no financial and administrative ties, whatsoever to the oil and gas industry, whose extensive research article entitled, "The Role of Human Factors Considerations and Safety Culture in the Safety of Hydraulic Fracturing (Fracking)", was published in a recent issue of the Journal of Sustainable Energy Engineering (September 2014).