Compliance Verification Activity Report: CV1920-142 - Pembina Energy Services Inc.

Overview

Compliance verification activity type: Emergency Response Exercise

Team:

• Inspector 2470

Regulated company: Pembina Energy Services Inc.

Operating company: Pembina Energy Services Inc.

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Emergency Management

Related events:

• CV2021-411

Rationale and scope:

As part of the NEB's annual compliance planning, Pembina Energy Services Inc. was identified for an exercise evaluation to verify the company's response capabilities during an emergency response exercise.

Compliance tool(s) used:

• None

Facility details

Facilities:

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)
• Valve site

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Plans And Procedures
• Emergency Response Plan (ERP)
• Pembina NEBC HVP Pipeline System ERP, supported by the Corporate Emergency Response Plan
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Overall Exercise Observations

Date & time of visit: 2019-12-03 08:00

Discipline: Emergency Management

Categories:

• Exercise Planning and Conduct
• Scenario Briefing
• Site-specific Hazards
• General Safety Briefing
• Scope of Exercise
• Participant Package
• Exercise Objectives
• Notification and Reporting
• Notification & Reporting as per EPM
• Incident Classification
• Communications
• External Comms Strategy
• Internal Comms Strategy
• Communications Equipment
• Coordination with Responders
• Safety
• Safety Plan
• Personal Protective Equipment
• Monitoring/Safety Equipment
• Post Exercise
• Debrief Meeting
• Collection/Filing/Completion of Documents
• Evaluation Against Objectives
• Response Management
• Roles and Responsibilities
• Emergency Procedures Manual
• Command and Coordination Centers
• Span of Control
• Chain of Command
• Response Priorities/Incident Objectives
• Response Structure
• Mobilization of Resources/Equipment
• Operational Period
• Meetings & Briefings
• Incident Status Board
• Maps and Modeling
• Response Tactics
• Site Layout
• Plans and Procedures
• Site Security/Access Management
• Control Points
• Hazard Monitoring
• Protection of People

Facility:

Observations:

The Pembina Pipelines Corporation Area Office in Fort St. John at 10919 89 Ave became the Incident Command Post (ICP).
The Calgary Head Office at 585 8 Ave SW (#4000) is the location of the Corporate Emergency Operatins Centre (CEOC).

Exercise Planning and Conduct
 

• The CER received both an initial introductory package for the exercise, and closer to the date of the event, a full participant package which has more details.
• In addition to exercise objectives, in the next section entitled 'Purpose', the participant package listed characteristics and components of the exercise. The section opened with the following overarching description:
• The FSX (Full-Scale) exercise will simulate an emergency response scenario allowing participants to actively assume a response role and participate in tasks assigned to that role.
• Exercise facilitation was provided by Sandhurst Consulting Inc. The facilitators staffed simulation cells in the ICP and the Corporate Emergency Operations Centre (CEOC), and field facilitator/observers at the incident site. The Exercise Director/Lead Facilitator briefed all the participants in the ICP on safety, exercise logistics, and the rules of play prior to the deployment to the incident site. Participants were encouraged to use available tools such as ERPs, role-specific guides and maps. The facilitator also reviewed the exercise objectives and goals. He stressed the importance of clear, concise communications.  Sandhurst Consulting had also provided ICS training to the participants at Pembina.
• The ICP for the exercise was the area office. The office is located in Fort St. John, close to resources and near the highway. The facility was equipped with numerous power and internet ports, an overhead projector, maps, ICS wall displays, colour-coded vests for specific roles, and break-out rooms (offices and small meeting rooms).
• The CEOC at HQ was equipped with role-specific vests, binders, and tables stored in labelled cabinets. The room has big screen monitors and projectors that projected GIS in addition to the paper maps on the walls.  There were wall- posted status boards and action trackers. The Emergency Operations Manager staffed an ICS structure that roughly mirrored the organization in the ICP and included two scribes. Initially the CEOC logistics, finance and liaison were not staffed, when they did arrive they were briefed by the Planning Support Chief.
• The scenario of the exercise was realistic consisting of a release of NGL (C2+ (ethane/ propane mix) from an 8 inch pipeline in a cultivated field with limited apparent human and environmental risk.  
• The incident site was approximately a half hour drive from the ICP near a point where the pipeline Right of Way (RoW) takes a radical jog to the south before turning east again to return to its original course.  There are two block valves on the pipeline in the area. Facilitators provided injects during the exercise to challenge the participants.
• Exercise initiation came through a simulated phone call from the Sherwood Park Control Center (SPCC) to the Incident Commander (IC) who would dispatch operators to the incident site to verify the site and cause of an odour complaint by a local resident.
• The location chosen for the incident site was near a dead-end street with one entry point which enable isolation and traffic management. As a result public safety was not a major factor in play although public protection was a prime objective of the exercise. The operators deployed to investigate the release site confirmed that they could see and hear the release. Sherwood Park Control Centre (SPCC) also confirmed a pressure loss, and closed the valves. The scenario identified a moderate south west wind.
• At the incident site the CER field observer did not record a safety briefing, safety meetings, or see a safety officer.
• In the ICP the incident was identified as a Level 3, and the EPZ set at 700M.
• In the field, the operators used professional judgement and natural barriers such as fence lines to arrive at a 400M EPZ. Two more operators were dispatched to verify closure of the main line block valves.
• Another operator would be deployed to establish a staging area at the north boundary of the EPZ, not visible to the operators at the initial site.
• In the CEOC, staff would later express, that they did not have a clear picture of the positions of field staff and their safety.
• The operators in the field maintained personal logs. The Emergency Operations Manager (EOM) in the CEOC also encouraged participants at the very start of the exercise to maintain formal ICS logs rather than personal notebooks.

• The incident was identified as Level 3 by the ICP team.
• The ICP staff employed the Emergency Response Notification System (ERNS) (E mail) to advise local residents to shelter in place and take usual precautions with respect to heating, ventilation and shutting in the gas supply. In the ICP, the simulation included using Pacific Northern Gas to shut off residential gas supply and to assist with shutting in water lines to prevent freezing.
• In the CEOC staff were tracking notifications to households and the shelter in place messaging. An ICS 233 activity log was projected to the room and completion of tasks was monitored.
• The CEOC determined that in only 1 of 7 households could shelter in place notification not be confirmed.

• The CER evaluator in the field did not see: a safety plan at the site, a safety officer or a safety briefing.
• Operators at the incident site wore basic PPE. Some wore hard hats. The evaluator did not observe reflective vests worn outside of coveralls; hearing protection in use, eye protection being worn or reference to personal monitors or readings (simulated). The vapour readings at site were a component of the scenario conditions. . The scenario provided that LEL readings were low enough to be safe outside the EPZ.
• Other safety equipment, such as vapour monitors and materials for roadblocks and signage were discussed but not in view. Likely sites for vapour monitoring with respect to the plume were identified. Operators who were deployed to the valve sites were advised to take SCBA as a precaution.
• Rovers were deployed to the incident site to confirm that local residents had received the ERNS message to shelter in place and to take appropriate precautions.
• In the ICP, staff were developing a plan for a Reception Centre in Taylor, and assigning staff and resources. ICP staff also considered local school children and rerouting school buses to the Reception Centre. The development of a reception center is advisable and it raises issues around managing residents who self-evacuate. In this scenario there was a single access road to simplify tracking movements.

• Operators in the field referred to field guides that were stocked in their vehicles.  The evaluator did not observe use of the ERP or position guides or checklists for initial actions. Operators had laptops that have an application that provides real time information about flow and pressure at valve sites but they weren’t in use at the exercise.
• The participants in the field all appeared to be experienced operators who are familiar with ICS and have received training and practiced using the system. The operator at site, one of two assigned to verify the release, expressed uncertainty about his subsequent role and responsibilities while his partner was assigned to the roadblock. He experienced problems in contacting the ICP while staff were in meetings. Leadership might have been able to clarify his role if they had been available when he phoned the ICP.
• An ICP was activated promptly and the Incident Commander (IC) assigned roles promptly in appropriate functions using an ICS-based organization structure. Participants wore vests identifying their role.
• In the ICP the IC began to staff roles and an ICS 207 was filled in as the structure was established. The structure reflected the ERP and the needs of the incident.
• Response priorities focused on public safety. And prior to knowing the exact location of the release Leadership identified issues of:
  • Weather and the wind direction of SW to NE.
  • Vapours, LELs, benzene
  • Residents, trappers, grazing lease holders
  • Messaging to the public
  • The local private airfield and possible ignition sources, and soon a local gun range was identified
• The intent was for the Planning Section to develop the ICS 201 briefing form quickly in order to enable the Liaison Officer to make notifications promptly.
• Operators were deployed to the field in specific roles as the operational needs became clear; examples, Rovers and Staging Area Manager.
• Outside resources were mobilized for vapour monitoring, and road blocks to relieve operators for other functions. For instance, Pacific Northern Gas was contacted to assist with shutting in gas lines and draining pipes to prevent freezing. Peace River Pat Protective Services were contracted to provide a presence at the Reception Centre.
• At the ICP, some incoming staff were allocated to the night shift; but it was not clear that any operational periods had been established and communicated.
• In the CEOC at 12:45 staff were tasked to schedule replacements for a night shift with a target of a 17:00 HR changeover.
• The IC initiated the ICP activation, and a 201 was being developed but he did not present an actual situation briefing to staff but he did provide one to the CEOC. The IC did review the objectives during the response.
• The General Staff met to consider the response and resources and also shared information and needs with the CEOC. However, the goals of meetings, and their required outcome was not always clear. The timings of meetings was not always shared with the ICP as a whole and the incident status was not posted or projected for the benefit of all participants in the ICP.       
• The ICP had a GIS operator who assisted the Rovers with identifying residences in the area of the incident site so that notifications could be confirmed (as a simulation only, the Rovers did not approach the homes).
• The ICP staff did not focus on developing and maintaining a common operating picture by employing situation unit to develop a detailed display, or by distributing updated reports and small scale maps.
• CEOC staff did maintain a situation display and project maps for the room. Staff tried to understand and anticipate the support needs of the ICP. 
• Participants and evaluators signed in and out at reception at the Area Office for the ICP and into and out of the CEOC at the corporate location.

• Field operators were able to communicate with the ICP using cellphones. Trucks are also equipped with SAT phones. Sound quality and cell reception were adequate at the incident site.
• The ICP was able to communicate effectively with the CEOC at Pembina HQ in Calgary. The IC relied upon the CEOC to provide resources and information such as: blow-down calculations, plume modelling and media statements. The ERNS appeared to be an effective tool for communicating with local residents near the incident site.
• The CEOC took a long time to develop plume modelling and to provide an estimated blow-down time for the ICP. Despite this lagging request, the participants in the CEOC were definitely focused on supporting the ICP. Leadership scheduled regular meetings with the ICP and the EOM briefed up to the accountable VP in 2 scheduled briefings.
• In the ICP the Liaison role was assigned and engaged in notifying agencies and regulators.
• The field operators decided to refer any media contacts that might occur at the roadblock or the incident site to the ICP even in advance of receiving holding statements. The Rovers were provided with a text to manage contact with residents with respect to shelter in place or evacuation.
• The CEOC prepared a news release, and various holding statements to be used at road blocks and the Reception Centre.

• The operators at the incident site discussed whether a local fire service would respond to the structure fire at the residence ignited by the plume. They were doubtful that any responders, either contract or municipal would attack the fire.
• At the incident site the operators accepted that only one other option was open and that would have been igniting the plume in order to reduce risk and possibly to save the destroyed house. However field operators are not equipped with ignition gear (flare guns) and did not pursue that option with the ICP.
• In the ICP leadership determined to wait for the line pressure to drop and accepted field reports, first of the size of the plume and direction of travel, and after ignition, of the damaging consequences and later of the shrinking size of the flames as the line pressure diminished. 
• The ICP focused on the safety of local residents, how to communicate with them, how to track their movement and evacuation and the safe deployment of field operators.
• In the ICP an inject raised the issue of livestock on properties near the incident site and the possibility of Rovers helping to wrangle horse herds. The CEOC was briefed on the issue.
• In reality, it does not seem that deploying Rovers to assist with managing herds (some of them large) would be advisable or successful.
• Later, in conversation with the CEOC, the ICP would consider a plan for compensating residents for lost livestock and engaged the LSU in the CEOC.
• Field operators at the site where the release was initially identified did not approach the RoW... Other operators who were assigned to confirm closure of the mainline valves, and isolation of the line, and those who deployed to the staging area including a Staging Area Manager, had control of the northern boundary of the incident site.
• The operators did not establish a site layout, beyond estimating the appropriate EPZ. At the site, the plume would have been tracked by sight and sound. The operators surmised that the wind direction would put the large residence downwind in peril. A later inject would self-ignite the release, and the fire would consume the residence.
• The ICP identified risk to the local airfield east of the incident site and requested a Notice to Airmen (NOTAM) for air traffic.
• The ICP also ordered lighting, security, fire services and water trucks to arrive at the staging area.
• Site security issues were not a concern along Craig Rd at the southern boundary; the northern boundary was controlled by operators at the staging area. 
• One roadblock was simulated at the entrance to Craig Rd sufficient to manage traffic on the dead-end road.
• The relevant valves were identified quickly, closed by SPCC, and closure was verified in the field.
•  In this gas release, containment, decontamination, waste management and human health receptors were not considered in the field.
• Vapour monitoring was engaged by the ICP through contractors.
• The field operators did not appear to consider environmental issues. While there was discussion about livestock, there was no discussion about wildlife protection.

• The debrief was delayed to allow field personnel, observers and evaluators and controllers, to return to the ICP so that they could participate. The comments were recorded by the facilitators. The format encouraged participants to identify successes and opportunities for improvement.
• The Exercise Director acted as facilitator and the IC committed to incorporating improvements identified into the ERP.
• Documents (primarily logs) and ICS forms were collected by the facilitators.
• The exercise was assessed against the exercise objectives. Consensus of the participants was that the objectives had been accomplished.

• Public notification through the use of Pembina’s automated notification system (ERNS)
• Identification and conduct of appropriate public protection measures
• Establishment of an ICS structure
• Effective communication between the incident site, Incident Command Post and the Corporate Emergency Operations Centre
• Development of an Incident Action Plan (IAP) for subsequent operational periods

• The ERNS is an effective tool to enhance public protection.
• Public protection measures, through notifications, roadblocks, Rovers, school bus diversions, public messaging, NOTAMS, Reception Centre were simulated well.
• The ICS structure was established promptly and appropriately in the ICP and the CEOC, perhaps less well in the field.
• Communications between the field, the ICP and the CEOC were effective with a few understandable glitches.
• An ICS 201 was produced but not shared with the staff in the ICP or the field. An IAP for subsequent operational periods was not posted or distributed and therefore it could not be evaluated.

• More training and practice with role-specific checklists could have prepared:
  • The lead field operator in his de-facto role as On-Scene Coordinator.
  • A Safety Officer in developing a Safety Plan for all deployed field staff.
  • A Situation Unit Leader in development and maintenance of a situation display and a common operating picture.
  • The Liaison Officer with facility in making prompt and accurate notifications to rights holders, agencies and regulators.
  • The Planning Section Chief with timing and coordination of the sequence of meetings and their outcomes and products; and the Planning Section staff with preparation of first the ICS 201 Brief, and then the multiple components of an IAP which is a complex undertaking.

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: