Compliance Verification Activity Report: CV2021-493 - TransCanada PipeLines Limited

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-493
Start date: 2020-11-03
End date: 2020-11-03

Team:

Regulated company: TransCanada PipeLines Limited

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

To evaluate the company's emergency response capabilities during COVID-19. In order to practice emergency response mobilization during COVID-19, TransCanada PipeLines Limited is conducting an exercise in its Rocky Mountain Region. The objectives are focused on initial (6-hour) response mobilization. A small outdoor initial field component in Medicine Hat and a physically distanced Regional EOC in Airdrie will take place. No full-scale Incident Command Post will be established. Given COVID distancing protocols, external participants have only been invited to the field component. Medicine Hat Fire Services and local elected officials have been invited to attend. If Medicine Hat Fire Services is able to attend, they will be invited to establish an initial Unified Command as part of the limited field component of exercise play.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - TC Energy Operation Gas City Exercise

Date & time of visit: 2020-11-03 08:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

On 3 November 2020 CER staff attended a Full Scale exercise in Medicine Hat, AB.

Unified Command (UC) was established with the CER, however, the initial UC invitation and briefing marked the end of the exercise. Allowing further progression into the response would encourage meaningful participation by Unified Command.
Exercise Planning and Conduct
The pre-exercise meeting commenced at 08:00 MST at the TC Energy Office in Medicine Hat, Alberta (AB). A site safety briefing was given and a participant package, including a complete outline of the scenario, was distributed. The exercise purpose, scope, objectives and ground rules were reviewed, both with the in-person and virtual groups. A comprehensive refresher outlining TC Energy’s Emergency Management Program was provided.  It was indicated that the intent was to practice how the Regional Emergency Operations Center (REOC) roles transition into incident management team (IMT) roles.

The exercise objectives included:

- improving initial field response capacity through mobilization of on-call technicians, completion of an Incident Command System (ICS) 201 briefing and transfer of command to an incoming TC Energy Incident Commander.

- practicing REOC notification, mobilization and initial field support capacities in a remote environment.

- demonstrating collaboration with local emergency services by conducting an incident briefing and establishing an initial Unified Command.

- identifying an initial Incident Management Team through transfer of REOC roles into an IMT and identification of regional IMT backup resources.


CER staff observed that TC Energy's objectives for the exercise, while appropriate for this scenario, appeared conservative and did not appear to have been designed to push participants further into response stages. Increasing the complexity of the objectives in future exercises would benefit participants in expanding their own capacity. 
CER staff observed that the exercise objectives changed due to complexities created by Covid-19. While these changes had been discussed with the CER, they were not communicated to exercise participants or reflected in the exercise documentation.
CER staff observed that while objectives were mostly met, the objective of demonstrating collaboration with local emergency services and establishing a Unified Command fell short of the CER’s expectations for a full scale exercise. CER staff are cognizant of the fact that the unique challenges of the pandemic, changing dates, and availability and willingness of external responders to participate can impact this type of exercise objective. Future exercises may benefit from simulating the expected involvement of outside agencies and responders in the event they are unable or unwilling to attend.
The scenario was based on a third-party pipeline strike and resultant gas leak in a busy industrial area. At 08:30 MST, Gas Control received a customer call reporting a loss of pressure near Cousins Meter Station South. Gas Control noted a 20-minute pressure drop from 4700 kPa to 4200 kPa on Supervisory Control and Data Acquisition (SCADA) system for the Suffield South Lateral NPS 20 Line. Gas Control dispatched an on-call technician to verify the release. The technician arrived and confirmed a probable leak and noted a third-party company had driven a pile on top of the line. The technician detected loud noises and saw debris coming out of the ground around the pile.

The field site was located at the Cousins Meter Station South. Those participating in the field gathered in designated observer and participant areas, company trucks for meetings, and the TC Energy Medicine Hat office before and after the exercise for briefings. Other staff established a REOC in Airdrie, AB and attended virtually as observers and participants. All sites followed strict Covid-19 protocols.
 
The exercise involved TC Energy staff as participants, evaluators and observers. In attendance from the CER were two staff participating in the field, including an Emergency Management Officer in Unified Command and an Inspection Officer evaluating, and an Emergency Management Officer observing in the virtual REOC. A TC Energy Simulation Center Line was established for participants to contact for exercise injects and when calling "external" parties.

CER staff observed that the exercise scenario considered potential hazards and situations realistic to TC Energy's operations and there was adequate time for the exercise objectives to be achieved. The participants were able to fully engage in the ICS process, the initial response process and REOC functions.
CER staff observed that TC Energy demonstrated a calm, organized process during the initial response stages. They made good use of the applicable ICS forms and conducted a thorough transfer of command. Communication remained focused and on task throughout the exercise.
 
Notification and Reporting
TC Energy Control Centre received a customer call reporting loss of pressure near the Cousins Meter Station. Gas Control checked their SCADA system and noted a loss in pressure in the line. Two TC Energy technicians were dispatched to the incident site. They confirmed the incident and began notifications as outlined in the Emergency Response Plan (ERP). The ERP was activated and company staff began establishing a REOC at the TC Energy office in Airdrie, AB.


An Online Event Reporting System (OERS) report was received by CER staff at approximately 11:45 MST. CER staff observed a discrepancy between the information from the Transportation Safety Board and the OERS and emphasized the importance of accurate reporting. CER staff reviewed criteria for immediately reportable incidents as defined in the CER Event Reporting Guidelines with exercise participants during the exercise debriefing meeting.

Safety 
Safety began with a detailed job safety analysis (JSA) created by the TC Energy Emergency Preparedness Team Members and endorsed by all field participants. This doubled as a sign in/out sheet and was controlled by one person, as no sharing of hard documents was permitted due to Covid-19 precautions. The field crew considered hazards at both the TC Energy field office location and the TC Energy field site relating to slips, trips, falls, hazardous atmospheres, hot/warm/cold zones, climate and environment. Appropriate personal protective equipment (PPE) was discussed and included hard hats, eye protection, gloves, coveralls, boots and personal gas monitors.

Safety and Covid-19 specific measures were discussed and outlined in the participant handouts.  Personal Accountability System tags were used for the field participants and observers to maintain accountability at all times.

Response personnel in the REOC and the Incident Commander at site were cognizant of start times for all primary responders to ensure that internal maximum work hours were not being infringed upon.
 
Response Management
ICS was used to organize and manage the response to the incident. Upon arriving on site and verifying the release, the technicians assumed the roles of Company First Responders and began initial response procedures and activities consistent with TC Energy’s Emergency Management Program Manual.  When the TC Energy Incident Commander arrived on scene, an efficient and detailed transfer of command was conducted through a formal briefing process. The incident was discussed with the Incident Commander and was classified as a Level 1 due to the following criteria: there was local media interest; the incident had potential to impact off of TC Energy property/ROW; and, control of the emergency may have deteriorated but imminent control of the hazard was probable. The situation was unlikely to escalate further. This is consistent with TC Energy's Emergency Management Program Manual. CER staff observed that the incident classification did not occur until 13:30 MST. Establishing the incident classification earlier would assist in "getting big quick", as well as help inform the other agencies’ responses.

Both field and REOC personnel understood and adhered to the chain of command and the process to request and order resources, as required. Resources such as personnel to staff an incident management team were requested through the logistics section. An operational period was established and staff put in resource requests early to ensure their positions would be filled (if required) for night shifts.

Incident response priorities and objectives were discussed and developed promptly. These priorities and objectives were further refined as more information became available during the course of the response. Considerations for staff and public safety, containment and environmental protection were discussed and planned for. The potential for the incident to escalate was also discussed from a safety and response perspective. The area of the incident was particularly challenging with neighboring facilities hosting a multitude of ignition sources, hundreds of staff and stockpiles of hazardous chemicals.

CER staff observed that TC Energy staff engaged Canadian Fertilizer in the exercise and one Canadian Fertilizer staff member came to site to discuss their facility and hazards.
 
Communications
Cell phones were used to communicate between field staff and the REOC. Radios were also available in the trucks to communicate between other TC Energy technicians.

Meetings between field and office/virtual response staff were concise, organized, focused on goals and tasks, included quick discussions of situation changes, and delegation of responsibilities and tasks.

Communications flowed efficiently from the field into the REOC. Upcoming call times were established on each call and the call backs occurred on time.

The Company First Responders requested media statements from the REOC to ensure consistency in the event of any media inquiries.
 
Response Tactics
Upon confirmation of the leak, the company dispatched technicians to shut in the closest valves for the pipeline upstream and downstream of the release in order to isolate the section. 

An initial isolation zone was discussed and determined to be 800m but was reduced to 200m once the pipeline was shut in and depressurizing. This isolation zone would be managed by the Medicine Hat Fire Department.

The Company First Responders established hazard zones and a staging area approximately 800m away from the incident site. Road blocks were established along the road nearest the site and evacuation routes for the neighboring facilities were discussed. Medicine Hat Police Services (MHPS) were contacted to aid with establishing/maintaining roadblocks. The MHPS were unable to attend in person for this exercise but did participate virtually. Air traffic and other area users were notified to remain clear of the area.

The Company First Responders at the site considered the hazards posed by the product released and established PPE requirements, including air monitors and site safety rules. They began requesting PPE, staging materials, clean up materials, additional personnel and mutual aid from Oil and Gas cooperative groups nearby to provide response equipment. They requested a security company to provide site security and they requested media statements from TC Energy communications.

There were two large neighboring facilities potentially requiring evacuation or sheltering in place. This was discussed with the Canadian Fertilizer employee participating in the exercise. It was identified that they would have anywhere from 100-450 staff at their facility 200m away from the release site. Canadian Fertilizer has internal procedures for ignition source control and shelter/evacuation.  Road traffic and rail traffic to the area would be impacted - either limited or cut off entirely - by TC Energy. Private security contractors would be utilized to maintain scene safety and limit exposure, depending on the wind direction and plume size.
 
Post Exercise
A debriefing meeting was held to discuss the learnings immediately following the exercise. The meeting involved the field, REOC and virtual participants and observers. Positive learnings and areas for improvement were discussed and noted. All documentation generated was collected and to be filed and reviewed by TC Energy emergency management staff.
The area where the scenario was located was a very complex region with two large, busy industrial facilities within 500m and a large public sporting forum outside of TC Energy’s 800m emergency preparedness zone. CER staff observed that if the scenario was worst case, this area would require evacuations or sheltering in place of hundreds of personnel and shut downs of a rail line and two industrial facilities with many ignition sources and hazardous chemicals present. The full scope of the threat this type of scenario poses in this location did not appear to be recognized by TC Energy participants and was a lesson learned following exercise engagement with MHPS and Canadian Fertilizer. CER staff encourage TC Energy to exercise in the area again and to give greater consideration to the potential impacts to neighboring facilities, or to ensure they have thorough emergency plans specific to that area that account for the complexities their neighbors and own operations potentially pose to one another.
 

Compliance tool used: No compliance tool used

Observation 2 - Information Request (IR) #1 - After Action Report (AAR)

Discipline: Emergency Management

Categories:

Facility:

Observations:

Please review the IR and provide the requested after action report by the specified date.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Please file the After Action Report (AAR) following the instructions in the Documents section to upload and submit by Feb 15th 2021. The AAR should describe:

-              the exercise scenario

-              player activities

-              preliminary observations

-              what could be improved on, based on:

o             observations and learnings from all exercise participants

o             recommendations for each observation/learning, or

o             an explanation as to why a recommendation/feedback will not, be addressed.

Due date: 2021-02-15

Date closed: 2021-03-29
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 3 - CER Observations

Date & time of visit: 2020-11-03 15:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

CER Staff made the following observations:

- Unified Command (UC) was established with the CER, however, the initial UC invitation and briefing marked the end of the exercise. CER staff noted that allowing further progression into the response would encourage meaningful participation by Unified Command.

- TC Energy's objectives for the exercise, while appropriate for this scenario, appeared conservative and did not appear to have been designed to push participants further into response stages. Increasing the complexity of the objectives in future exercises would benefit participants in expanding their own capacity. 

- The exercise objectives changed due to complexities created by Covid-19. While these changes had been discussed with the CER, they were not communicated to exercise participants or reflected in the exercise documentation.

- While objectives were mostly met, the objective of demonstrating collaboration with local emergency services and establishing a Unified Command fell short of the CER’s expectations for a full scale exercise. CER staff are cognizant of the fact that the unique challenges of the pandemic, changing dates, and availability and willingness of external responders to participate can impact this type of exercise objective. Future exercises may benefit from simulating the expected involvement of outside agencies and responders in the event they are unable or unwilling to attend.

-There was a discrepancy between the information from the Transportation Safety Board and the OERS and emphasized the importance of accurate reporting. CER staff reviewed criteria for immediately reportable incidents as defined in the CER Event Reporting Guidelines with exercise participants during the exercise debriefing meeting.

- The incident classification did not occur until 13:30 MST. Establishing the incident classification earlier would assist in "getting big quick", as well as help inform the other agencies’ responses.

- If the scenario was worst case, this area would require evacuations or sheltering in place of hundreds of personnel and shut downs of a rail line and two industrial facilities with many ignition sources and hazardous chemicals present. The full scope of the threat this type of scenario poses in this location did not appear to be recognized by TC Energy participants and was a lesson learned following exercise engagement with MHPS and Canadian Fertilizer. CER staff encourage TC Energy to exercise in the area again and to give greater consideration to the potential impacts to neighboring facilities, or to ensure they have thorough emergency plans specific to that area that account for the complexities their neighbors and own operations potentially pose to one another.





 

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