Compliance Verification Activity Report: CV2122-180 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-180
Start date: 2021-04-27
End date: 2021-04-27

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:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

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 Design

On 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:

The exercise began with introductions by TC Energy leadership, Indigenous communities, industry partners, Grande Prairie Emergency Services, and the CER. A job safety analysis (JSA) was reviewed, and COVID-19 safety protocols and control measures were presented. These included:TC Energy discussed their response goals, identified as LIPS - Life Safety, Incident Stabilization, Property & Environment preservation, and Stakeholder Communication. An overview of the TC Energy emergency response structure and response evolution was provided along with information on how the company classifies an emergency.

Lessons learned from previous exercises were identified and it was explained how those were being incorporated and had helped inform the exercise.  MS Teams’ use, functionality and etiquette were discussed; providing participants with the information required to navigate the areas of the MS Teams platform that would be utilized for this exercise. An ICS refresher ran throughout the morning and all participants or observers not directly involved with exercise play were in attendance.

Exercise Facilitation and Control

Exercise facilitation and control was sufficient and there was an appropriate number of staff and controllers to simulate the required aspects of the exercise. As noted above, the exercise facilitator reviewed the scenario, objectives, and rules of play. A safety briefing was conducted and included the review of the job safety analysis, hazards, COVID-19 safety, and controls and mitigations. Record keeping was demonstrated by forms uploaded to MS Teams and participants were encouraged to fill out the ICS 211 (Incident Check-In List) to log in and out of the exercise. 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. 

Exercise in Play: Notification and Reporting

Players worked collaboratively to classify the incident. Using the emergency classification and emergency score matrices from the Emergency Management Corporate Program Manual, the incident was classified as a level 1 emergency at 11:06 MST. 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 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. 

Regulatory notifications were made to the Transportation Safety Board (TSB) at 10:22 MST and the CER received the notification via the online event reporting system (OERS) at 12:07 MST. 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.
 
Exercise in Play: Safety

Safety remained a priority throughout the exercise. Given the virtual nature of this exercise, players and participants were reminded of personal safety considerations in their home offices and players located in company offices appeared to be observing COVID-19 social distancing recommendations.

Exercise in Play: Response Management

TC Energy used ICS to organize and manage the response to the incident. An ICS Form 201 (Incident Briefing) was observed to be in use early in the response.  Verification of the incident occurred at 09:43 MST and emergency services were notified by 9:55 MST Considerations for evacuation of the immediate area were discussed and a precautionary 800m emergency planning zone (EPZ) was established. The initial size of the EPZ was due to several unknowns, including: the leak rate; pipeline size; capacity; and containment. As additional information was determined, the EPZ was downsized accordingly. The final EPZ assessment was downsized to 300m once it was confirmed that the leak had occurred on an NPS 6-inch line and was contained within the facility. As noted above, Company staff went through the established response actions including connecting with the gas control, which initiated all required notifications processes. TC Energy’s ‘Company First Responder – Responsibilities and Action Checklist (GAS)’ was used to track company initial response actions.  

Incident response priorities and objectives were discussed and developed promptly. These priorities and objectives were further refined as more information became available throughout the response. Initial objectives were identified as:Players adapted as more response information was made available and adjusted the tactics as required, such as decreasing the EPZ based on the confirmed conditions (e.g., pipe diameter).
 
Assigned roles were consistent with the company’s Emergency Management Corporate Program Manual. 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.

The IMT was stood up at 11:50 MST. A transfer of command began at 11:55 MST and was completed at 12:05 MST.  CER staff noted that the ICS 207 (Incident Organization Chart) was completed as a group effort. This group work was somewhat unique as it was an open forum for discussion and for staff to volunteer for IMT positions with assignments established through group consensus.

Unified Command was established comprising the Company IC the CER IC. The CER IC spoke to the CER’s mandate and was asked about potential limitations and constraints within the response setting. 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.

The EOC Briefing was well structured and informative. However, CER staff observed that establishing a meeting schedule that identifies the time, required attendees, type of meeting and is posted in an easily accessible spot would facilitate a smoother transition in and out of meetings and ensure that all necessary parties are present. Following a prescribed agenda and being mindful of the time would also assist in keeping exercise play in motion. Once UC was established, key meetings were conducted between 13:00 and 14:53 MST. Meetings included an initial IC/UC meeting, an IC/UC meeting to review objectives and a Command and General Staff briefing.

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. Recognizing that backgrounds can impact bandwidth and may not always be available to use, it’s important to ensure that external parties are aware of who is filling each role. A comprehensive ICS 207 posted in an easily accessible spot is an additional way this could be achieved if the use of backgrounds is not possible.

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.

Exercise in Play: Response Communications/External Communications

TC Energy primarily relied on cell phones and virtual communications through MS Teams and the Everbrite event notification system. These methods were effective, however, given the virtual environment it was difficult to observe what was going on as players typically muted their microphones while conducting communications. 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.

Communications with external stakeholders were conducted by cell phone and through MS Teams communication for those in attendance at the exercise. 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.

Exercise in Play: Tactical and Strategic Response

The Company demonstrated interoperability and a clear understanding of company versus industry roles through its interactions with the industry partners in attendance at the exercise. Appropriate strategies and tactics were discussed, and both the Company and industry representatives recognized the collaborative value of being part of the response from the onset. The Company maintained situational awareness and adjusted the response as new information became available or when conditions changed.

Exercise in Play: Public Protection

Public safety concerns were identified and an initial EPZ was discussed, established, and adjusted as required to protect the responders and the public. The Royal Canadian Mounted Police (RCMP) were notified and dispatched to the incident to block access. It was identified that the closest residence was just outside 600m, which ultimately was outside of the adjusted EPZ.  The closest structure within the downgraded 600m EPZ was the Tidewater Facility. The facility was informed and made the decision to shut down operations and evacuate.

Post-Exercise

An exercise debrief was conducted and all participants were given the opportunity to contribute. During this process players identified several successes, challenges, and areas of opportunity.

The Company noted that exercise objectives were largely met and made the following observations regarding its completion of each objective.

1. Practice virtual initial response procedures in a COVID environment through completion of an ICS 201 briefing and use of virtual notification, communication, and documentation tools.

-Executing each of the required actions took longer than expected and at times were more difficult to communicate than anticipated. However, players were flexible and adjusted quickly to the challenges (i.e., filling out forms by hand and scanning to the file when they were unable to be collaborated on within MS Teams). 

2. Collaborate with industry partners to develop continuity of service strategies at a critical site for Grande Prairie service deliveries.

-Industry partners provided great technical advice and both industry and the Company found there was a benefit to early involvement. Both industry partners were pleased with how the response was executed and felt that the collaboration was effective. This ultimately streamlined the process and a repair plan was developed quickly.

3. Collaborate with attending local authorities, Indigenous communities, and stakeholders by conducting notifications and practicing ongoing liaison activities during response. 

-It was noted that this objective was only partially met as not all notifications were made. An opportunity for improving the capacity to conduct notifications was identified. 

4. Leverage technical expertise from TC Energy Pipe Integrity to ensure exercise participants are aware of all potential contingency solutions. 

-Overall, it was felt that embedding the repair planning into the exercise was effective. It allowed technical staff to get a jumpstart on planning and ultimately a plan was already discussed prior to the objectives being set.

Compliance tool used: No compliance tool used

Observation 2 - Canada Energy Regulator (CER) Observations

Discipline: Emergency Management

Categories:

Facility:

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:

The AAR should also include improvement planning such as a corrective action plan (CAP), that identifies program improvements and the necessary corrective actions required to address them, and an improvement plan, identifying the corrective actions to be taken, the responsible party or agency, and the expected completion date.

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

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