Compliance Verification Activity Report: CV2122-174 - Utility Group Facilities Inc.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-174
Start date: 2021-10-14
End date: 2021-10-14


Regulated company: Utility Group Facilities Inc.

Operating company:

Province(s) / Territory(s):


Rationale and scope:

<p>Verify compliance with OGOA and the UGFI Operations Authorization through an assessment of the application of the Ikhil Operations Emergency Response Plan during a tabletop exercise.</p>

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Emergency Response Exercise Evaluation

Date & time of visit: 2021-10-14 14:00

Discipline: Emergency Management




Exercise planning and conduct
On 14 October 2021, TriSummit Utilities Inc. (TriSummit) conducted a tabletop emergency response exercise (TTX) based on a simulated emergency on the Ikhil pipeline.  Ikhil Operations (gas wells, pipeline and distribution system) are regulated by the Canada Energy Regulator (CER) within the Inuvialuit Settlement Region and by the Northwest Territories Office of the Regulator of Oil and Gas Operations (OROGO) within the Gwich’in Settlement Area. The certificate holder for the CER-portion of the operations is Utility Group Facilities Inc (UGFI). Inuvik Gas Limited (IGL) runs the distribution system.  Staff are shared between the two companies with TriSummit providing the overarching management of Ikhil Operations.

Although the initiating event of the simulated emergency did not occur on the section of the pipeline regulated by the CER, the responders involved and the emergency response plan (ERP) that applies to the Ikhil Operations are the same. In addition, the CER and OROGO have a memorandum of understanding which supports coordination in their respective onshore jurisdictions.

The exercise was conducted over Microsoft Teams, with company responders grouped together in an IGL meeting room in Inuvik and the remaining participants joining from their place of work, including the Ikhil Asset Manager (a contract employee of UGFI). External agencies that attended included the contractor and facilitator (Wotherspoon Environmental), OROGO and the CER. The Inuvik Fire Department was invited, but unable to attend.

From the TriSummit – Ikhil ERP Emergency Response Exercise document, the objective of the exercise was to assess the operational capability of Ikhil Operations personnel to respond and manage an emergency incident involving communications issues, missing operations personnel, and the potential release of natural gas. Specific sub-objectives included:

  1. Identify the severity and potential impacts of an emergency
  2. Plan appropriate initial response actions specific to the incident
  3. Identify the location of the Incident Command Centres would be
  4. Determine applicable response objectives
  5. Develop a communications plan with responders and stakeholders
  6. Assess the capability of TriSummit personnel to respond to an incident
  7. Identify successes observed during the exercise
  8. Identify gaps and areas for improvement in the emergency response systems
The initiating event for the exercise involved a line strike from a piece of heavy equipment resulting in a gas release and an alert from Supervisory Control and Data Acquisition (SCADA) that the inlet pressure was reducing at the Gate Station.  CER staff noted that the players refuted the reality of there being low inlet pressure at the station. After discussion, it was concluded that this inject was not realistic. CER staff also observed that the scenario for the previous year’s exercise (referenced in the Ikhil Operations Emergency Response Plan) also involved a low inlet pressure.  Exercise planners should develop realistic scenarios if this is indeed unlikely. Similarly, players should be advised, and accept, that unlikely scenarios are still possible and that the objective of an emergency response exercise is to manage the result of the initiating event, in this case a release of gas, and the consequences associated with the event, which can be similar across multiple event types.

Notifications and Reporting
Notifications to TriSummit, OROGO, CER, Town of Inuvik, Inuvialuit Regional Corporation, ATCO (as one of the joint venture owners of IGL), the territorial 24-Hour Spill Report Line, and the Transportation Safety Board were discussed by the Incident Commander and Asset Manager.  Agencies identified were consistent with those listed in the ERP. 

The players were familiar with the properties of the product in the pipeline and understood the need for setting roadblocks and controlling access to the event location, for public safety and for preservation of the scene for investigation purposes.

Response Management
Once the players had investigated the scenario sufficiently to determine that this was a pipeline emergency, they started to refer to the Ikhil Operations ERP.  This included assigning staff positions in the incident command structure (Incident Commander and Operations Chief) and looking at priorities and objectives.  Later, another position was assigned as scribe, which does not appear in the ERP.  During the exercise debrief, the exercise facilitator referred to the term “Unified Command” which was not recognized by the players. This term is used in the ERP which leads CER staff to believe that players are not sufficiently familiar with the facility’s ERP or that the emergency response procedures that staff are trained in differ from those in the ERP. This is potentially problematic.

When UGFI/IGL started looking at priorities and objectives, the number one concern was security of supply, as the gas from this pipeline is used for heating. The priorities presented in the ERP follow the PEAR structure (People, Environment, Assets, Reputation) and this was not discussed during the size-up of the incident.  Later in play, objectives for the response were identified as 1) security of supply, 2) isolation of the pipeline and 3) security of the incident site. At no time during the discussion did players discuss the potential for injury of the operator of the heavy equipment which damaged the pipeline. The players explained that they didn’t address this as there wasn’t an inject to explore that aspect of the event.  Following the PEAR priority structure, assigning someone the role of Safety Officer, and having the Fire Department in attendance may have caught this oversight.

After referring to the ERP, a level one emergency was declared by the UGFI/IGL Incident Commander. UGFI/IGL uses the AER Emergency Classification Matrix.  According to this matrix in the ERP, a level one emergency is considered low risk and does not include pre-determined public safety actions. 

The documentation of the incident was discussed, with critical times being captured throughout and a full debrief of response activities happening afterwards, once staff return to the office. IGL staff would submit an incident report to the TriSummit Asset Manager.

UGFI/IGL staff shared their expectation that public communications regarding the event would not be required by the company until after the incident was resolved.  They stated that the event would be over before information could be disseminated and that they do not want to escalate concern during an emergency. In response to an inject about public concerns of drinking water impacts, UGFI/IGL took the position that addressing this concern is not part of emergency response as it is only quelling nerves of the general public, who are afraid of gas, and that there would be no drinking water impacts as gas is lighter than air. Instead, UGFI/IGL would work with the Town to issue a statement that they are focused on the response to an emergency.  After the emergency is over the Ikhil Asset Manager would ask TriSummit corporate communications to prepare and issue a press release. CER staff are of the view that in absence of an announcement from the company, that other entities and the public will control the messaging about the incident and the response. In addition, given the way information spreads in a small town, it is advisable for the company to work with the Town to release information as soon as possible to the public, including boundaries of the exclusion zone, general information on the product, who to contact with questions, etc.  The advance preparation of a general holding statement, that can be tailored to the circumstances of a specific event, identifying that the company is aware of the incident and that they are working with the Town, can minimize the draw on time from the core response group on site.

Response Tactics
As injects were presented and the scenario progressed, players discussed their actions in general terms, until prompted by the facilitator to go into more detail. The facilitator was well prepared to ask leading questions to encourage players to explain why they took certain actions.  This resulted in the players demonstrating their competency in describing the operational steps required to shut down the pipeline and start up the propane alternate supply system.  It appeared that the staff have a long history of working together and understand the roles that each play in the daily operations of the facility.  Player feedback was that field staff are not talkative, know what needs to be done and would rather do the work than talk about it.  

The exercise inject concerning the Happy Valley Campground impacts was assessed as unrealistic by the players as the campground is closed at this time of year.  Exercise planners, when developing injects, should validate their viability with a trusted source who knows the local area.  Not doing this compromises the exercise as players will spend more time fighting the scenario than discussing response actions. Accepting that this could be an impact at a different time of year, players noted that the Inuvik Fire Department would be responsible for evacuations and that an assessment of vulnerabilities would be undertaken. Players identified that assistance may be required from the RCMP to conduct broader evacuations and that setting up roadblocks would require external assistance given that IGL has four staff in the field to conduct the response: one who would stay at the incident site, two others to bring the propane alternate supply system online and isolate the pipeline, and another at the gate station to monitor pressure.  

Post Exercise
The last hour of the event was spent debriefing the exercise.  The players had the opportunity to share their thoughts, the facilitator shared an overview of their observations, and CER and OROGO were invited to share their initial feedback.

The players at site are confident they already know what to do in the event of an emergency and believe the exercise evolved as a real emergency would.  They recognize that the Fire Department would play an increased role in managing the site as they have more authority for public safety. CER staff observe that the UGFI/IGL responders appear to be a well-functioning team, who are aware of the different roles that each member fills in response to an event. 

In an emergency, coordination and communication across agencies can be vital, especially in a situation where human resources are limited. The company reported that they have done a lot of work with the Fire Department and that they have an excellent relationship. However, it was not possible to validate the level of common understanding of roles and responsibilities between the two organizations because the fire department was not present to confirm their actions.

CER staff are of the opinion that the exercise objectives were partly met.  Areas of improvement include:

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to:

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program