Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
To verify response capabilities during NGTL's Full Scale exercise in Grand Prairie (Wildrose Region), AB on 27 April 2021. The scope of the exercise includes testing the ability of the company's response program, including plans and personnel, to an emergency event involving its Canada Gas Operations.
Compliance tool(s) used:
Facilities:
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Operation Crabby Hermit - Emergency Response Exercise
Date & time of visit: 2021-04-27 08:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
Exercise Planning and DesignOn 27 April 2021, three Canada Energy Regulator (CER) staff attended the TC Energy (Company) virtual full-scale Wildrose 2021 Regional Exercise: “Operation Crabby Hermit”, in Grande Prairie, AB. The simulated scenario for this exercise involved a leak on a sales gas line. In attendance at the exercise were representatives from TC Energy, the CER, Indigenous communities (Treaty 8 and Métis Nation of Alberta), industry partners (ATCO and Tidewater), Grande Prairie Fire Department and the Grande Prairie Regional Emergency Partnership.CER staff requested and received an exercise participant package prior to the exercise date. This package included scope and purpose, milestones, virtual format and check-in procedures, safety, objectives, scenario and maps, communication rules and documentation, and exercise rules of play and assumptions. The exercise objectives were attainable, measurable, and realistic for the exercise and the scenario was designed in consideration of the hazards and risks posed by the company's operations. TC Energy engaged potential exercise participants ahead of time, through planning meetings, MS Teams access tests and ICS training if requested.In advance of the exercise, CER staff attended multiple planning meetings and were invited to actively participate, with one staff filling the role of Federal Incident Commander (IC) in Unified Command (UC). Local responders, key stakeholders, industry partners, and Indigenous Nations were invited to the exercise.The company’s planning process determined the scope of the exercise would include the following virtual components:
Compliance tool used: No compliance tool used
Observation 2 - Canada Energy Regulator (CER) Observations
CER staff observed the following:CER staff noted that reminders to participants regarding expected use of forms and reiteration of the need to follow the established documentation processes would have helped to ensure that internal documentation expectations are met. CER staff noted that two classification systems were discussed. One to classify the incident as a level 1 emergency and another pipeline integrity system that classified the leak as a level 3 leak. CER staff noted that it would be beneficial to ensure that all participants are aware of the differing classification systems that will be used ahead of time to reduce potentially confusing one with the other when classifying the incident. TC Energy is reminded of the principle to “get big quick” and consider classifying higher in the initial stages and scale back as required. This principle ensures that the appropriate people, plans, and resources are in place as soon as possible.CER staff observed that while this notification was received in under three hours as required by the CER’s Event Reporting Guidelines, the Company is reminded to submit the OERS report as soon as possible and to update it as more details become available.CER staff observed that, in some cases, players were apprehensive about how to proceed in their assigned roles within the virtual context. Additional training sessions to clarify task completion specific to assigned roles in a virtual EOC environment would likely help to ease the transition for staff used to working in a physical EOC to working in a virtual EOC environment.CER staff observed that including the CER, the lead federal regulator in this scenario, in UC was not automatic and the Company is reminded to consider this in future exercises. CER staff observed that visible role identification was not present for critical roles. While CER staff recognize that the virtual environment can be challenging, making use of visual aids, such as color-coded backgrounds to denote specific IMT functional role assignments, would assist participants in easily recognizing the various sections that individuals are part of. CER staff observed that there appeared to be no dedicated incident status board available for viewing. Making use of the tools available through MS Teams to ensure that an electronic/virtual status board is created and made available to all participants would assist in the dissemination of information and ensure participants have the information they require.CER staff observed that to facilitate “exercise play” it would be beneficial if call traffic were left open where possible and only muted when there is too much noise to conduct the call. In those cases, it’s important that players come back and describe the steps that were taken and what was discussed or ensure that the ICS 214a’s (Individual Log) are promptly completed and made available to all participants. This maximizes the training value, promotes interoperability, and improves the dissemination of information.CER staff observed, and the Company LO noted, that the public holding statement took a long time to develop and was not available for UC to review until 14:30 MST. This delayed the Indigenous Liaison providing notifications and relevant information to Indigenous communities. CER staff are of the view that once sufficient information is available to confirm that an incident has occurred and that an emergency response is underway, initial notifications should commence without further delay. Subsequent follow-up and information sharing can occur once more information becomes available and resources such as the public holding statement are approved for sharing and dissemination.TC Energy is requested to consider these observations in the after action report.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Company action required:
TC Energy is requested to file an after action report that considers the observations indicated in the report and the information as indicated below.Follow instructions in the Documents section to upload and submit the AAR by 01 Sept 2021. The AAR should describe:
Due date: 2021-09-01
Date closed: 2021-09-01 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
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