Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Foothills Pipe Lines Ltd.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
As part of the CER's annual compliance planning, Foothills Pipe Lines Ltd. was identified to verify the company's response capabilities during an emergency response exercise. TC Energy (current corporate name) held a full-scale exercise to train its staff and learn from local first responders in Crossfield AB on 1-2 Oct 2019.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Crossfield Full-scale Exercise Evaluation
Date & time of visit: 2019-10-01 08:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
Exercise Planning and Conduct An Exercise Evaluation Team of the Canada Energy Regulator (CER) attended a full scale exercise hosted by TC Energy in Crossfield AB, 1-2 October 2019. This team consisted of an Inspection Officer (the Officer), an Emergency Management (EM) Specialist, a Communications Officer (Coms Officer), and a Safety Technical Specialist. The exercise was held to meet the company’s requirement to demonstrate compliance to s.32-35 of the Onshore Pipeline Regulations. A Situation Manual and Exercise Plan were available and shared with the CER before the exercise. Other attendees included: company participants, industry participants (Enmax), facilitators, several coaches, the Alberta Energy Regulator (AER) and local first responders. The exercise occurred over a 2 day period where each day concentrated on separate aspects of a response. This format gave most observers the opportunity to witness both the field response activities, the Incident Command Posts (ICPs) and the Regional Emergency Operations Centre (REOC) response processes which would have otherwise occurred in separate locations concurrently during an actual emergency. On Day 1, the exercise structure was discussed and additional information on TC Energy’s pipeline and storage facilities was provided for participants. This first day consisted of command training for some participants and some initial response activities, including onsite response by operators, establishment of the company’s REOC and Corporate Emergency Operations Centres (CEOC). Prior to the exercise commencing on Day 2, the facilitator went over the scenario, objectives and, rules of play (e.g. exercise duration, exercise artificialities, simulation, injects, participant roles, when to call the exercise over, how to stop the exercise (in the event of a real emergency) and the need for external communications to clearly identify that a real incident had not occurred. A pre-exercise safety orientation was conducted at Collicutt Siding Golf Course before responders were dispatched to the specific incident location (the site). This orientation included how to access first aid, site emergency procedures and any situations that would result in suspension of the exercise. The orientation was comprehensive, thorough and applicable to the hazards and actions to be expected throughout the day. At all exercise locations participants and observers checked-in utilizing the two tag system, where and individual would leave a tag at the check in location where they were present and at the entry of any hot zones identified. Day 1 included the company’s immediate incident response and the set-up of an initial ICP at the Crossfield Storage Facility. The REOC and CEOC were also established at the Airdrie and Calgary offices respectively. While other participants were at the release site and at the ICP where exercise inputs and initial response actions were occurring, members of the Incident Command: Command and General Staff who were scheduled to be activated on Day 2 when Unified Command (UC) would be established, underwent ICS section-specific training. Day 1 ended with a transfer of command from IC to IC which was repeated the next day so all participants and observers could experience it. Day 2 consisted of the transfer of command from both the initial Incident Commander (IC) and initial ICP location to Company manager and a larger operational site (Collicutt Siding Golf Course). Morning activities also included activation and resourcing of a full ICS structure in the ICP. Again, this set-up allowed initial responders, who were involved in Day 1, the opportunity to observe and learn another perspective of response management. Notification and ReportingNotifications from the ICP during Day 1 were completed in a timely and organized fashion. The pipeline release was confirmed and notifications to the REOC and Gas Control were made by operators immediately upon arrival to the Crossfield Storage Facility. While the responders located at the ICP were completing the ICS 201 form, both the RCMP and Fire Department (FD) were identified as requiring immediate notification in order to quickly get resources on site to support the response with traffic control and air monitoring resources. All other agency and resource calls were completed by either the REOC or CEOC as per Company EM procedures which employs both Centres to support initial in-field response actions until a full ICS structure is resourced. During Day 1 activities, the level of emergency was not determined in an observable way to the CER team but was confirmed as completed later in the day. Company staff provided supporting information that classification is part of the CEOC activities, which were not observed by CER evaluators. Safety A safety plan was developed for both the exercise and the simulated actions within the exercise. Safety briefs were provided at all exercise sites on both days 1 and 2. A unique contribution to the exercise was a list of safety “do nots” in addition to the standard list of safety “dos”. During the ICP Command staff refresher training on Day 1, the company presented lessons learned from previous incidents such as the Nixon Ridge release in the U.S. It was apparent to the CER Officer that safety lessons learned from those events were being rolled out in Canada and at the Crossfield exercise. Upon initial response an emergency planning zone (EPZ) of 800 m was established and air monitoring was established at this demarcation and individual units were required on personnel entering the EPZ. At this time the company coordinated with local RCMP to establish road blocks based on this 800m and integrated RCMP input into their planning and operations. On Day 2 a FD “strike team” was assigned air monitoring verification in order to reduce the 800m to 4 and then 200m. As mentioned above, company procedures established a supportive REOC while initial response actions occurred, this reduced the scope of work and multi-tasking typically required by initial on-scene technicians. The CER’s Safety Technical Specialist noted that response’s identification of hazards and implementation of controls was thorough and well executed throughout the two days. The Technical Specialist also noted that after the release was contained, and immediate threats to public and personnel safety were resolved, company staff then moved to ensure public mental health and well-being were considered and addressed. The Officer notes that this is an emergency management best practice occurring more frequently across North America. Response Management At the onset of the incident, the Operations Staff located at the initial ICP (Crossfield Storage Facility) were observed activating their Emergency Response Plan by first verifying the gas release and completing the 201 ICS briefing form. Thus activating the REOC and requesting support from TC Energy Gas Control, local RCMP and FD assets thereby quickly increasing the ICS structure to promote and expedite a competent response. Once additional assets arrived on-site, Unified Command was established between TC Energy, and the local Fire Chief which was to ensure actions followed the ‘priority of response’ as indicated by L.I.P.S. (Life Safety. Incident Stabilization, Property and Environmental Preservation and Stakeholder Engagement) as outlined in the TC Energy Emergency Response Plan (ERP). TC Energy also invited the RCMP into UC but they preferred to be there as an observer to improve their support efforts but not guide or direct the response. The systematic use of pre-determined forms and processes was observed throughout the initial operational period at the ICP which allowed incident information to be relayed to the REOC. Update calls between the ICP and REOC occurred frequently and sometimes lasted for more than 20 minutes at a time which was seen to tie up ICP response momentum. For future incidents and training, the ICP needs to ensure that such update meetings are pre-scheduled and limited in duration to allow each response team the additional time to complete objectives set out for the operational period rather than being on the phone. The company also activated their mobile ICP trailer which set up a complete and self-sufficient post. This included computers, section table markers, ICS vests, situation update boards, printers and ICS organizational posters. As noted above, the end of the Day 1 saw a completed Transfer of Command and ICP location, a vital step required for prolonged and larger responses. This process was observed to be slow and methodical, allowing the incoming Incident Commander the ability to interject and ask questions. The Transfer of Command process included all members of UC which provided a venue in which all pieces of pertinent incident information were passed on and properly documented. Day 2 of the training focused on the second ICS/ICP operational cycle which started with a replay of the Transfer of Command. At this time the CER, was invited into UC, the role of CER Incident Commander was played by the Inspection Officer. Next came an initial situation update and progression into several scenario injects which continued throughout the day. The ICP, adopting UC, and driven by the Planning Chief, utilized the TC Energy’s Emergency Response Plan to effectively navigate through the cycle of the ICS planning ‘P’. This included the activation of all Command and General staff within the ICS structure and definition of overall objectives developed by Unified Command. The Planning Chief then promptly activated the Documentation, Resource, Situation and Environmental Unit Leads to begin development of strategy, tactics and resource documentation which eventually lead to an approved Incident Action Plan. Planning, Tactics and related pre-meetings were scheduled and held on time and to exact timings. The development of an approved Incident Action Plan (IAP) by the end of the exercise was above the initial goals of the exercise and was attributed to the hard work of participants and the overall design of the exercise. Response Tactics Response priorities identified at the ICP were defined as; maintain 800m EPZ, maintain wildlife stewardship, continue air monitoring and maintain preservation of evidence. Once the release was confirmed, the ICP’s initial priority was public safety and isolation of the EPZ. The Incident Commander notified and mobilized first responders to provide initial road blocks and air monitoring units. This was accomplished by setting up road blocks on highway 2A, 800m (later 200m) to the north and south of the release to prevent any public from entering the area. TC Energy’s initial responders then proceeded to complete the following public safety measures:
Compliance tool used: No compliance tool used
Observation 2 - Response Management
Date & time of visit: 2019-10-01 09:00
For future incidents and training exercises, the initial ICP should have pre-scheduled update meetings that are limited in duration to allow each response team the additional time to complete objectives set out for the operational period rather than being on the phone.
Observation 3 - Response Tactics
The initial staging area was identified to be at the Collicut Siding Golf Club however this was deemed to be a poor choice as the initial reponders, who were staged at that location, were delayed getting to the incident site due to being caught behind a train that was passing through the area. This observation was deemed a lesson learned that was immediately changed in the incident response. Future planning should identify train tracks or other potential impediments to movements of personell and equipment.
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
