Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Whitecap Resources Inc.
Operating company: Whitecap Resources Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
To verify compliance with the OPR at a full scale exercise near the Boundary Lake Field Office.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Emergency Response Exercise Evaluation
Discipline: Emergency Management
Categories:
Facility:
Observations:
Exercise overview, planning, and design – Facilitation and Control On 22 September 2021 Whitecap Resources Inc (Whitecap or the Company) conducted a full-scale exercise based upon its Northern Alberta / Northeast BC Emergency Response Plan (ERP) in the Boundary Lake Area. This simulation provided Whitecap an opportunity to test the ERP, evaluate the Incident Command System (ICS) for overall incident management, and to verify its First On-Scene Actions and Five Step Initial Response Guide. The exercise, and the challenges presented by the scenario, also served to demonstrate operational capabilities and the testing of standard operating procedures and response tactics. In attendance at the exercise were Company personnel, external consultants (H2Safety) to facilitate the exercise and CER staff. The exercise was executed at three locations: the Incident Command Post (ICP) in the Boundary Lake Field Office, a field site, and the Emergency Operations Centre (EOC) in Calgary. CER staff attended all three locations. No external stakeholders or responders participated in the exercise, but the Company indicated that they were contacted ahead of time to determine their level of interest and availability for participation. Most stakeholder interactions were conducted through a simulation cell. Participants were encouraged by the consultants to facilitate external interactions where possible for the purpose of added realism, verifying response capabilities and supporting the exercise learning objectives. CER staff in the ICP observed Company staff actively making calls to confirm resource availability. This action allowed Company staff to provide realistic expected arrival times as well as to determine various capacity and capability changes to local area emergency response service providers for future updates to its ERP. The exercise began with sign-in and introductions, rules of play, safety and COVID-19 measures and mitigations, a review of the exercise goals and objectives, and the scenario. Except for identifying traffic on Cecil Lake Road potential real-life hazards, controls, safety equipment and PPE were not discussed. Introductions included participants sharing how many years of experience they have, identifying their role within the company and their individual level of ICS training completed. The simulated scenario for this exercise involved a leak from a pipeline that impacted multiple roads and waterways in the Boundary Lake area. Desired response actions included the need to address the safety of company personnel, responders, the public, environment and to apply technical knowledge to manage the leak. CER staff received limited information in advance of the exercise and had to prompt both the Company and external consultant for details and information. The Company is reminded to ensure that CER staff receive the requested information, participant package and any other supporting documentation by the date requested in the initial email. Notification and Reporting The Company activated an emergency response and determined the level of emergency in accordance with its emergency procedures manual (EPM). The incident was classified as level 3 using both the BC and Alberta classification matrices contained within the EPM (due to the incident being on the border.) There were no impacted stakeholders in the immediate area, however, the Company called the residents in the nearby area to inform them of the incident. Company personnel made the notifications as indicated in the EPM, including Whitecap corporate notifications, Emergency Management British Columbia, BC Oil & Gas Commission, Alberta Energy Regulator, Western Canadian Spill Services, and the Transportation Safety Board/CER. CER staff observed that Whitecap personnel in the ICP were aware of the CER online event reporting system (OERS) requirements but were unfamiliar with using the system itself. Whitecap personnel specified a need for more familiarity with the online event reporting form, including required fields and information to have available and indicated it would be beneficial to include prepopulated information, specific to OERS entry, in the role packages for quick ease of reference and to facilitate earlier reporting. CER staff recommended conducting a notification exercise with key staff who may be tasked with reporting and making use of OERS in future exercises to add realism and build comfort with using the system and the requirements of the reporting. CER staff in the EOC noted that there was productive discussion in the EOC on CER reporting requirements and on how the EOC can support the ICP including potentially taking over the regulatory reporting requirement. Safety CER staff in the EOC observed that safety of the responders and impacted stakeholders was identified as a priority for the response. Whitecap EOC staff also affirmed with the ICP, and the field, that the safety of the responders and the public remained the number one priority during the response. EOC staff also prompted the ICP and field staff to consider the potential for the incident to escalate in magnitude or complexity.
In the ICP, CER staff observed that Company personnel identified the product as a sour liquid release. CER staff did not observe where the SDS or additional product information was located, including product specific characteristics, considerations, potential receptors, First Aid, and PPE requirements. (See IR #1) In the field, CER staff did not witness a tailgate safety briefing prior to initiating response activities, although sign-in to access the site was required. Field responders used SCBA and personal monitors to approach the simulated spill site. Responders were paired and used voice communications when conducting initial reconnaissance of the spill site. The Safety Officer came to the field around 11:45 PST to discuss safety with the responders at the designated staging area. He addressed: H2S, wildlife, slips and trips, emulsion chemicals, requirements for special gloves, high visibility clothing, spotter requirements and cautions on soft ground. When asked about the procedure for what would happen if someone became contaminated with oil, the response was that the individual would be driven back to the main office to decontaminate in the showers there. The field medic was approximately 21 km away at other site (Boundary Lake Field Office). Safety zones (hot/warm/cold) were not identified at the site. When CER staff asked Company responders about the location of the hot zone, the answer was that it was at the intersection of the pipeline ROW and the company road that ran almost perpendicular to the ROW, where the company truck was parked, less than 100m from the simulated spill site. CER staff asked how the company informs contractors, such as vacuum truck operators, of the hazards and risks associated with the product and the spill site. The Whitecap site lead in the field indicated that a work review is conducted and a permit issued for the activities to be undertaken by the contractor before the job starts. The site lead also indicated that they are using contractors they are familiar with and both the contractors and Company personnel have had a mutual orientation to operations. CER staff observed that the EPM, Incident Command System (ICS) 201 Incident Briefing Form and the ICS215a Incident Action Plan Safety Analysis contained safety information, including information and prompts for the consideration of protective zones and decontamination. CER staff observed that Company personnel were unfamiliar with protective zones and decontamination procedures. (See NNC #1) Prior to leaving the Boundary Lake office for the field, CER staff picked up a copy of the “Recommended Infection Control Measures for Responders in the Field During COVID-19 Pandemic”. This document was created by Emergency Response Assistance Canada in March 2020 and the safety officer had drawn attention to this document, for which several copies were available, during the morning exercise safety briefing. In the field, the control measures as identified in these procedures were not followed by company responders: masks were not worn when responders were gathered within 2m of each other, and several responders were observed eating from the same bag of chips that was sitting in the back of one of the company pick-up trucks. During the safety meeting held later that morning, some responders were wearing non-medical masks and others were not. This was not corrected by the Safety Officer. (See NNC #2) CER staff observed the required emergency signage for the pipeline on either side of the road that intersected with the ROW near the incident site. When the number on the sign was called, the call went to voicemail for an individual’s private mailbox. (See NNC#3) The same emergency number was on both signs. When CER staff compared the number on the signs to the one in the current ERP they were different. The company committed to updating the signs as soon as possible. Response Management Company personnel responded in accordance with their EPM and made good use of the tools available to them including the EPM, wall charts, visible role identification (vests), forms, newly developed role kits and job aids. The Company used ICS to manage the response. CER staff observed that most Company personnel demonstrated basic knowledge and a willingness to use ICS. CER staff note that this was a continued improvement from previous exercises. During introductions, CER staff observed that many Company personnel have ICS 100 training with some having ICS 200 training. Prioritizing additional training for key personnel, including ICS 300 and role specific (i.e.: Incident Commander, Planning Section Chief, Safety Officer) training would continue to improve overall ICS understanding. CER staff observed that key elements of response were not discussed as the focus was on immediate operational tactics and strategies. Given the simulated release volume and product migrating offsite and into marshlands, CER staff are of the view that it would have been beneficial, as part of the exercise, to: establish operational periods, set objectives beyond the initial stages of the response, and preplan for other aspects such as waste management, site security, decontamination, repair plans, and remediation. CER staff also noted that these elements are also considerations that could assist in meeting the Companies stated objective of developing a resource plan that includes the use of Support Services. CER staff noted that there appeared to be a disconnect between how information was perceived and actioned (discussed) between the ICP and the field. For example: Company personnel in the ICP identified area users, cattle, and other wildlife as well as sensitive areas, wetlands, and a marsh that feeds a larger water body as considerations and/or potentially impacted areas that could impact the response. However, upon learning of the higher incident classification, Company personnel in the field did not identify the same concerns or appear to be responding with the same level of urgency. CER staff observed that combining certain roles, such as the Liaison Officer and Information Officer, resulted in unachievable expectations due to the time commitment and work required for each role. It was recommended by Company personnel that, given the requirements of these roles, they should be kept separate to facilitate staff in executing the requirements of each one. CER staff support this recommendation. CER staff observed operational expertise and significant local knowledge held by certain individuals who are assigned key roles in the incident management structure. These individuals automatically assumed tasks outside of their assigned role or were leveraged by other company responders in conducting tasks required by their role in the company’s incident management structure. While this expertise and local knowledge is invaluable, its important to ensure that any information pertaining to a response (i.e.: contact information, preferred vendors, area residents etc.) resides in procedures or other documentation and is known and available to all responders. Having other Company personnel shadow these individuals assigned to key roles in future exercises (i.e.: Incident Commander) can build capacity on the incident management team. In addition, leveraging the local knowledge and expertise of more experienced staff via coaching would also be beneficial to increasing overall response capacity. Response communications technology Cell phones were identified as primary communications for the exercise with a brief discussion on using radios if needed. CER staff observed that a contingency communications plan was largely downplayed due to concerns with radio chatter and a belief that cell service was sufficient at the field location. As such, this option was not fully developed, including establishing a common operating frequency and ensuring that all participants had access to a radio. However, it was noted by CER staff and Whitecap personnel that cell service at the field location was spotty and was identified as an area of improvement. Tactical and Strategic Response Exercise facilitators indicated that the Company response team was briefed on the hazards in the area and used SCBA to mitigate the H2S hazard as they mobilized to investigate the incident site. Company responders worked in pairs to conduct safety checks on the SCBAs and thoroughly inspect face masks - including a positive and negative pressure test to verify the integrity of the seals. The incident site was contained and isolated to ensure that only response personnel entered the release area. A check in process was used to account for personnel and PPE was worn to protect the workers from the simulated spill, including SCBAs and personal gas monitors. Straw hay bales were used to act as a berm for mitigation and spill containment. A roadblock was established near the incident site. Company personnel had appropriate equipment and PPE for the spill response activities and deployed roadblock kits suitable for an incident of extended duration. Exercise facilitators noted that roadblock personnel followed the media cards when responding to questions and were diligent with maintaining records. Roadblock personnel continuously conducted air monitoring and communicated this information to the Public Safety Group Supervisor in a timely fashion. In the field, responders had a copy of multiple safe work permits pulled from the contain / control kit. These copies included: wildlife, excavation, and liquids recovery. Having permits prepared in advance can facilitate a response, but it is vital that the content is communicated with the responders. The communication of the content to the responders was not observed by the CER at the site. EOC CER staff in the EOC noted that the EOC functioned effectively in its support role to the ICP and field site. EOC staff checked in frequently with the IC as to how they could be of assistance but the EOC was also sensitive to not overstep its bounds in supporting the ICP. The EOC also asked relevant questions of the IC and staff to facilitate an effective response and ensure that more strategic considerations were not overlooked in the ICP and the field. The EOC also provided external communications and media support for the ICP and field. It was noted by Company personnel that the EOC felt underutilized and more effective utilization of the EOC was noted for further consideration in future exercises and incidents. Post Exercise A debrief was held at the end of the exercise. Exercise participants identified what worked well and what needed improvement, and these were captured for future exercises and continuous improvement. Whitecap personnel maintained document control using forms, the H2Safety Common Operating Picture Application and through emailing or texting documents and pictures as required. All documentation was collected at the end of the exercise.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
After Action Report Whitecap Resources Inc. is requested to file an after action report. Follow instructions in the Documents section to upload and submit the AAR by 04 March 2022. The AAR should describe:
Due date: 2022-01-04
Date closed: 2022-09-12 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
Observation 2 - Information Request (IR) # 1
See Company Actions below.
CER staff observed that the SDS and safe work permit were included as part of the documentation package that was provided to the CER following the exercise. Please describe where this information was located and how it was communicated to Company personnel, displayed, and used during the exercise.
Due date: 2022-03-04
Date closed: 2022-03-18 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.
Observation 3 - Notice of Non-compliance (NNC) #1
Date & time of visit: 2021-09-22 09:00
CER staff observed that Whitecap personnel participating in the development of the 201 seemed largely unaware of the expectations or need for decontamination in response to the simulated spill. Company personnel made no mention of establishing a warm zone or ensuring that appropriate decontamination equipment and resources were available. CER staff note that the recommendation that contaminated personnel return to the ICP to shower is an unacceptable mitigation measure and creates additional risk and contamination. CER staff also note that decontamination is part of Whitecaps ICS 201 and further described in the ERP under Section 4: Emergency Response Procedures.
Compliance tool used: Notice of Non-compliance (NNC)
Whitecap Resources Inc. will provide the following information:
Follow the instructions contained in the link to the compliance verification report to upload and submit the information requested above by the specified due date.
Observation 4 - Notice of Non-compliance (NNC) #2
CER staff observed that many of the company responders were not practicing the infection control procedures in the field that the company provided. This was during the same period that COVID infections in Northern Health Unit and in Fort St. John were rising.
Whitecap Resources Inc. will assess the implementation of the infection control procedures that the company is using to determine where the failure occurred. Provide a corrective action plan in writing to the CER by 04 March 2022 on measures that will be taken to prevent the introduction of and spread of COVID-19 in the workplace and in the field.
Due date: 2022-03-18
Observation 5 - Notice of Non-compliance (NNC) #3
Emergency signage for the pipeline did not have an accurate emergency number posted. This presents a serious hazard and contravention of the OPR (section 36(f)) as anyone witnessing an emergency at a location with incorrect signage will waste time trying to contact the company through an outdated number. CER staff directed the company to check all signs and have them updated within 48 hours.
Whitecap Resources Inc. must:
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
