Compliance Verification Activity Report: CV1920-331 - Whitecap Resources Inc.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV1920-331
Start date: 2019-12-11
End date: 2019-12-11

Team:

Regulated company: Whitecap Resources Inc.

Operating company: Whitecap Resources Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

As part of the CER's annual compliance planning, Whitecap was identified to verify the company's response capabilities and understanding of ICS as a result of a subsequent exercise evaluation.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Whitecap Resources Emergency Response Exercise

Date & time of visit: 2019-12-11 13:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Exercise Planning and Conduct

On December 11, 2019, between 13:00 and 16:00, Whitecap conducted a table top emergency response exercise at the Boundary Lake Field Office. The scenario was a simulated oil/water emulsion release spotted on Boundary Lake near the BC/Alberta border NE of Fort St. John, BC. The initial incident reporting call was made at 13:11 from a hunter in the area, which was subsequently confirmed by Whitecap personnel to be a 10x50 m skim on the north side of the lake.

A participants’ package was received from Whitecap on Friday, November 8, 2019. This identified the location of and directions to the exercise and the participant list. The scenario was also identified and included overarching objectives along with sub-objectives for each expected stage of the exercise: initial response, incident briefing, clean-up response, continued response and debriefing.

Prior to commencing the exercise, the facilitator gave Canada Energy Regulator (CER), British Columbia Oil and Gas Commission (BCOGC), and Whitecap personnel a briefing on what to expect and the general rules of play. Given that the exercise was a tabletop, all personnel were located in the Boundary Lake Field Office. The tabletop was functional in nature and Whitecap personnel were separated into various locations, including: an area for the Emergency Support Team (EST) to simulate corporate involvement from the head office in Calgary, an Incident Command Post (ICP) combined with field location, and a ready room for participants to wait until they were brought into play. While the CER recognizes the value of maintaining situational accuracy in bringing participants in at their expected stages of the response, there would also be benefit for participants not in play to shadow or observe as a learning opportunity to gain a better understanding of the overall ICS structure and reinforce previous training.

Exercise Objectives:
The main objectives of the exercise, as identified by the Company, were established in response to comments and recommendations made in compliance verification activity 1819-502 and consisted of:

In response to these objectives, Whitecap personnel utilized a complexity analysis that assisted them in identifying the priorities, problems, objectives, strategies, tactics and resources (PPOST). This worksheet was useful in helping determine what roles were necessary for the response and allowed each individual to focus on the duties of that particular role.

Notification and Reporting and Emergency Response Manual

Emergency Response Procedures (ERP) were available to participants and used appropriately as required. The incident was initially classified as Level 3 according to the classification matrix in the ERP and later downgraded to Level 2 as more information became available and the incident was stabilized.
 
Whitecap simulated notification of the appropriate regulatory agencies and exhibited a good understanding of who to call and why. Notifications were made to company and regulatory personnel in a timely fashion. Transfer of command between the initial responder and the incoming Incident Commander occurred at 13:35 with additional participant deployment occurring at 13:55. While there can be benefit to notifying personnel early, CER Staff are of the opinion that the extra time spent sizing up the incident, confirming ownership and working through a complexity analysis in a methodical, step-wise fashion was a good start to setting up a well-organized response structure. CER Staff also recognize that some personnel, in a real-time situation, would likely have already been onsite, aware of the situation and awaiting further direction.
 
Notifications to BCOGC were conducted and maintained by the EST. The current Whitecap ERP indicates that regulatory notifications would be done through the IC or the Liaison Officer. In cases where the ERP is not being followed, it should be clearly identified who will be conducting what notifications.

Safety

Given the nature of the exercise, a formal safety plan was not developed for this scenario. It was established that there were no residents in the area and no one in the emergency planning zone (EPZ). There was one old trap line that had been taken over by the province and was no longer active. Road blocks were set up to keep the public from accessing the area.

No Safety Officer (SO) was assigned for this exercise. Safety responsibilities resided with the On Scene Commander (OSC) who relied on the ICS 215a and safe work permits. CER Staff are of the view that the Safety Officer role should be formally identified within the Incident Management Team to highlight the importance of the continued safety of personnel and responders. Should the IC be filling this role or designating it to the OSC, the ICS 207 Org Chart should clearly reflect this so all personnel are aware.
As the event occurred over at least 3 operational periods with night operations, CER Staff are of the view that a formal safety plan, which incorporates Whitecap safety procedures, should have been prepared. Such a plan allows for a more comprehensive assessment and implementation of safety measures that considers all participants in the response, including those external to Whitecap, and atypical working conditions.

Response Management
 
Whitecap personnel made concerted efforts to utilize the ICS tools available to them throughout the response. This included the use of the Whitecap ERP and Staff Truck Guides, as well as the appropriate identification of personnel through the use of vests, forms and wall displays.

Assignment of participants stayed within an appropriate span of control and while limited due to the nature of the exercise, chain of command was observed by participants. Compared to the last exercise evaluated by CER Staff on October 17, 2018 (CVA# 1819-502), the company showed improvement in assigning ICS roles instead of specific tasks. Those roles then made use of the complexity analysis that had been completed to ensure that priority and specific tasks that had been identified were addressed. Participants were willing to embrace their assigned roles and made use of the ICS tools available, filling out the appropriate forms, and keeping wall charts up to date.

An Incident Status Board was maintained for the exercise and maps were available on the walls. An ICS 207 organization chart was utilized well. CER Staff recommend that contact lists be posted near the chart and remind the company that this chart needs to be routinely updated to ensure accuracy.

It was noted that the product spilled was an oil/water emulsion; however, there were limited details posted regarding the product after that. CER Staff note that clearly identifying what the product was, displaying safety data sheets and the extent of the spill on the incident display board would assist in determining an appropriate EPZ, strategies and tactics.

Various meetings took place throughout the exercise; however, there was a lack of consistency in how each participant communicated the purpose and outcome of each meeting. Meetings occurred in various forms, either face to face, via text or by phone call. CER Staff are of the view that the exercise would benefit from formalizing or identifying which meetings are occurring and having a consistent method of communicating out the information (this could be in the form of a more developed incident status display board).

Participants worked through three operational periods. Participants did a good job with the shift turnovers and the transferring of command to the next shift. The incident briefing at each handover was concise and informative and allowed the new shift to immediately step into the response.

Communications
 
Communications for this exercise were conducted by cell phone, text or face to face. To try and maintain exercise roles, participants were encouraged to text each other, even when in the same room, to simulate how they would actually be communicating with each other in a real life scenario while at the same time not interrupting exercise play around them. Communications with external agencies, such as BCOGC, were done via cell phone. These were conducted by the EST in a separate room.

Response Tactics

As of 13:28, no gas readings had been conducted and CER Staff are of the view that this should have been identified as an immediate priority in order to ensure the safety of both the public and responders. In addition to this, confirmation that the initial caller had left the area did not occur until 13:29. CER Staff recognize that details of the incident needed to be determined, but are of the view that the initial caller, as a member of the public, should be immediately informed to leave the area and move upwind of the spill.

Upon learning of a potential release, Whitecap proactively isolated the line to limit product release.

The company was able to establish a link between the priorities/objectives identified for each operational period and the strategies and tactics required to execute and achieve these. Appropriate resources for product recovery were identified and requested as required.

Overall Observations

The EST indicated that scheduled check-in times from the ICP to the EST would be beneficial.  In previous exercises, Whitecap personnel established the next check-in time before ending each conversation. CER Staff agrees that re-implementing that practice would be beneficial to aid in effective communication. Even in cases where there may be little to no change to report, having an established check in time will help keep all parties aware of the situation.

CER Staff identified that command staff, in some cases, were located in the field as opposed to the ICP. Whitecap confirmed that in a real event, this would be an operational reality. While the CER recognizes this, it is important to consider how the required information transfer will occur and establish a method of getting this information from the field into the ICP. Suggestions at the end of the exercise included texting where appropriate or taking pictures of forms if necessary.

Overall, Whitecap personnel showed improvement from previous exercises and has demonstrated its responsiveness to previous CER observations and suggestions. There was a commitment to implementing ICS while still ensuring a safe and effective response that was realistic to the company. Whitecap stated that many personnel had received ICS 100 and 200 training and spill deployment equipment training. Personnel would benefit from continued training to enhance their familiarity with common ICS terminology and understand the responsibilities of each role. A chart identifying what forms are to be completed, when and by whom, that includes internal forms such as the A1 Initial Emergency Form, would also be a great benefit to personnel.

CER Staff intend to evaluate Whitecap’s full scale exercise in 2020 to assess the coordination between the ICP and the deployed field resources.
 

Overall, Whitecap personnel showed [JB10] improvement from previous exercises and has demonstrated its responsiveness to previous CER observations and suggestions. There was a commitment to implementing ICS while still ensuring a safe and effective response that was realistic to the company. Whitecap stated that many personnel had received ICS 100 and 200 training and spill deployment equipment training. Personnel would benefit from continued training to enhance their familiarity with common ICS terminology and understand the responsibilities of each role. A chart identifying what forms are to be completed, when and by whom, that includes internal forms such as the A1 Initial Emergency Form, would also be a great benefit to personnel.
CER S[JB11] taff intend to evaluate Whitecap’s full scale exercise in 2020 to assess the coordination between the ICP and the deployed field resources.

 

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