Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Plains Midstream Canada ULC
Operating company: Plains Midstream Canada ULC
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
To evaluate Plains’ response capabilities during its full deployment exercise on a water body and observe their Spill Response Equipment training and Incident Command Post operations.
Compliance tool(s) used:
Facilities:
Facility Types
Regulatory requirements that apply to this activity:
Observation 1 - Exercise Planning and Conduct
Date & time of visit: 2019-06-27 08:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
On 27 June 2019, the National Energy Board (NEB) attended a Plains Midstream Canada (PMC) full scale emergency response exercise in Leduc/Telford Alberta. NEB Inspection Officers were on site at the Incident Command Post (ICP) in Telford and at the incident site for onwater boom deployment at Wizard Lake Provincial Park. The exercise was a requirement under the National Energy Board Onshore Pipeline Regulations (OPR). However the exercise was also intended to satisify requirements for the provincial regulator and the upcoming revised Environment and Climate Change Canada (ECCC) Environmental Emergencies Regulations (E2 Regs). The exercise included establishment of the ICP and deployment of personnel with equipment to the incident site, and it tested the company’s ability to respond to an emergency and work effectively with first responders.An exercise participant package was distributed prior to the exercise date identifying exercise objectives which were attainable, measurable and realistic for the exercise. The exercise scenario was designed in consideration of the hazards and risks posed by the company's operations. The simulated scenario for this exercise involved a release from an NEB regulated line, PMC's Milk River Line, into a waterbody. The simulation was held in a different geographic location than the actual line to enable company staff to train and prepare for responding to a release into a waterbody, which would have been difficult to simulate near the actual line as it is in a drier area in the south of the province. At the ICP, the exercise facilitator provided a thorough introduction to the Full Scale Exercise, identifying the Unified Command Section (UC and Command Staff), Operations Section, Logistics Section; Finance/Administration Section areas. The ICP tables and meeting areas were easily accessible, providing a very conducive communication environment.As mentioned in the opening meeting section, the exercise scenario commenced on day 2 of the response. Starting on day 2 was intended as an added challenge for participants; an Incident Action Plan (IAP) developed on the simulated first day was used to guide operations during the exercise. The simulated first day included initial equipment staging at the incident site and establishment of the ICP in Telford AB and the plan was for equipment to be deployed on day 2. Inclement weather was the simulated rationale for no deployment during the initial response. The simulated first day IAP also included goals and objectives which were reviewed and refined during the actual exercise. Participants worked to create a revised IAP for day 2. NEB staff participated in the company's incident mangement system (Incident Command System (ICS)), were invited into Unified Command (UC) and functioned as observers/evaluators at both the ICP and Incident Site. Prior to the exercise, the facilitators 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 stress that a real incident had not occurred. Site security and public safety were adequately considered for the scenario and physical enviromental conditions at both the ICP and incident site. At the ICP and incident site, participants checked in and wore passes on lanyards. Invited participants included the Alberta Energy Regulator (AER), Tsuut'ina Nation Fire Rescue, Counties of Wetskiwin, Leduc and Red Deer, local Fire and Police, Alberta Health Services, Alberta Emergency Management Association (AEMA) and Sundre Pipeline Operators Group (SPOG). The majority of these organizations were not able to attended. The AER, AEMA, Alberta Health Services (by phone) and County of Leduc were in attendence. The AER were also invited into UC, however as discussed in the initial meeting it was their suggestion that the NEB take on the lead regulatory agency role in UC. A pre-exercise safety orientation was conducted during the morning. Weather was being monitored and operational safety components were prioritized so participants could deploy to the field with ICP safety considerations presented following their departure. This included how to access first aid, site emergency procedures and situations that would result in suspension of the exercise. The orientation was comprehensive and applicable to the hazards that could be encountered throughout the exercise.
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
Prior to the actual exercise, PMC used the TSB and NEB reporting system to exercise their notification proceedure. For exercise purposes, most internal and external notifications that would typically happen on day one were simulated to support a day two start. The level of emergency was appropriately determined to be a Level 3 in accordance with the company's Emergency Response Plan and Incident Classification Matrix.Notifications were conducted as per the Emergency Response Plan and were placed in an appropriate time. However, the online notification contained multiple time zone references within the event description (MST, MDT and EDT) which made the timeline more complicated. This was partly an artificiality of the exercise as the simulated incident occurred at 0100 EDT but exercise play occurred at 1300 EDT
Observation 3 - Safety
Security and safety planning was a priority for PMC at both the ICP and at the incident site. PMC staff were present and actively monitoring participants and entrances at the site and at the ICP.No safety tripping issues were observed at the ICP as proper and safe placement of electrical/communication cables was done.Upon check in at the incident site, a Field Level Hazard Assessment (FLHA) briefing was delivered by PMC staff, including a Health and Safety Site Plan and muster points, First Aid, gas monitors, traffic and access awareness, general site hazards, wind conditions, hot zone and PPE requirements. Attendance of all participants and observers was strictly monitored. All personnel signed forms to acknowledge that they had received the FLHA. Midway through the exercise, an inject involving a simulated caualty with breathing difficulties required dispatch of a medic and reassement of public safety measures by Command staff. They were able to review current air monitoring in place and determined it was adequate and vapour levels were below critical safety thresholds but additional communcation regarding possible odours and health effects to vulnerable community members was implemented as a further precaution. It was helpful to have local expertise in UC to discuss how notification and information would be shared with the public in a real event. During field response activities, PMC personnel showed familiarity with all necessary processes for safe work practices and notification procedures needed for emergency response at this valve site. NEB staff noted that there could have been more visible demarcation of the hot and cold zones at the deployement site but that this may have been due to exercise artificialities and the need to keep the boat launch area clear of obstruction.
Observation 4 - Response Management
The exercise began with a simulated Incident Comander (IC) handover by company staff. The company IC for the day then invited the AER and NEB into Unified Command (UC). When the representitive for the County of Leduc arrived, they were invited into UC as well. The AER and NEB ICs discussed the NEB playing the role of lead regulatory agency in UC even though the exercise included company facilities regulated by both agencies. In UC, the incident commanders discussed notification of appropriate authorities and roles and responsibilities involved with an order to "shelter in place". It was a useful discussion to understand the requirements of the county and City of Leduc regarding applying and lifting a "shelter in place" order and information required for decision making at the municipal level. A Unified Command (UC) was established between PMC, NEB, AER and the County of Leduc. All four Sections (Planning, Logistics, Finance/Admin and Operations) of the ICS were staffed by PMC and NEB. As this exercise simulated day two, priorities, objectives and roles were already established and assigned but reviewed that day by the company Incident Commander (IC). The initial actions of command staff were to implement the previous days IAP while monitoring the situation in real time to refine the priorities and objectives for the IAP in development for day 2. Section Chiefs and other roles were identified in the ICS 207 organization chart.Day 1 objectives and priorities were reviewed for appropriatness, or completness and a working set of refined objectives and priorities were developed by UC in a collaborative and consensual manner. Meetings such as UC, Tactics and Planning were run efficiently; roll call was taken and meeting rules were communicated. At the meetings, a clear linkage was provided between the work to be undertaken and the objectives established within an operational period. The live stream of field activities helped provide a visualization for meeting discussions. The main ICS forms were used as needed, such as the ICS 201 Incident Briefing form and ICS 214 Individual Log form. Ongoing status updates were verbally communicated during briefing meetings to participants in the ICP and on the status board. These ongoing status updates and live stream were beneficial for responders arriving on site as they did not have to wait for the next briefing meeting to obtain information on the incident. Wall charts, wall maps and a digital mapping system and spill trajectory modelling and posters were effectively used.Environmentally-sensitive receptors at risk were pre-identified in the day 1 IAP and participants developed mitigation to protect those receptors which saw, in one case, onsite responders deploy protective boom to a simulated receptor on the lake shore. This activity was documented using an ICS 232 form – Resources at Risk. The GIS unit also printed maps with updated information and visual representation, as the exercise progressed.All members of UC stressed the need for an integrated response that included all key players with response roles. Starting on day 2 was a different experience for participants and verifying details from the simulated day 1 was required at every step. For instance, the IC from the County of Leduc proposed that the public safety unit in the operations section be fully staffed to ensure no steps were missed from the simulated first day.The incident management team addressed the exercise inputs efficiently through open dialogue at meetings and by the responsive development of new plans as required. NEB Staff are of the view that this was a very positive outcome of the exercise and demonstrates the recognition amongst the players of the need for appropriate collaboration and cooperation during a response as part of the broader “EM system.”NEB Staff noted that the flow of the exercise followed the appropriate steps of the Planning “P” and meetings were efficiently held. PMC's execution of ICS demonstrated a thourough knowledge of the system. ICS was fully implemented and PMC demonstrated a thorough internal knowledge of ICS and also had access to an on-site coach with expertise in ICS. The Planning Section Chief and Operations Section Chief were new to their roles and should be commended for their conduct in these positions.
Observation 5 - Communications
Overall, NEB Staff noted that exercise communications were good. Participants noted that the Operations and Planning Sections dialogue was particularly good.TSB and NEB notification systems were used to maximize training value for particpants. Other simulated notifications was realistic and the PMC invited the representitive from the County of Leduc immediately into UC, which served to enhance the response and exercise learnings through a local communcation requirement perspective. With UC established, and in order to meet the exercise objectives, NEB Staff observed that the Public Information Officer (PIO) was efficient in addressing communication needs for the incident. An NEB staff member served in the ICS communciations section as a public information officer (PIO). PMC found this very helpful and the NEB IC in UC was well prepared for the press conference and media scrum held before the lunch break. Company personnel adequately prioritized internal communications ensuring all affected stakeholders were informed, demonstrating appropriate responsiveness relative to the scenario. The company’s efforts to promote collaboration among all agencies and support those involved, positively contributed to the overall success of this exercise and its communications activities.
Observation 6 - Response Tactics
The simulated day 1 included severe weather that prevented any physical response to the release. Therefore all tactical measures were deployed on day 2 during the actual exercise. The tactics chosen were in line with the companies documents and appropriate for the scenario and conditions. In addition:
Observation 7 - Post Exercise
Following the exercise, a debrief was held at the ICP. Exercise participants provided feedback on what worked well and identified areas for improvement.Highlights noted by particpants include:
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
