Compliance Verification Activity Report: CV2122-337 - FortisBC Huntingdon Inc.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-337
Start date: 2021-11-09
End date: 2021-11-09

Team:

Regulated company: FortisBC Huntingdon Inc.

Operating company: FortisBC Huntingdon Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

To evaluate response capabilities during its full scale exercise held on 9 November 2021. There will be 2 locations, one in Surrey (EOC) and one in Abbotsford (ICP). Approximately 10 people in each location. This will be a good opportunity to engage/network with the CBSA, USBP, Abby PD) and the Fortis' new EM program manager. The purpose of the exercise is to: Test and confirm activation of the Huntingdon Inc. Transmission Pipelines ERP • Test and confirm immediate actions at site level • Test and validate notification procedures as outlined in the FortisBC ERPs • Meet regulatory compliance requirements • Practice Unified Command at the Incident Site Participation may include: • Interior managers • Gas Ops • Gas Control • Corp Sec • Transmission Ops • Gas Supply • EORs • PAET (w/ Community Relations, Major Accts) • ELT External: • Abby Fire, Abby PD • CBSA, USCBP, Whatcom County, CER, BC OGC, Enbridge • Sumas Emergency Contact List members as observers • West Coast, North West Pipe (on Sumas Emergency list)

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Exercise Observations

Date & time of visit: 2021-11-09 08:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Observations
FortisBC Huntingdon Inc. held a full-scale exercise on 9 November 2021. The field component of the exercise was held at the Huntingdon station on Whatcom road in Abbotsford BC and the Emergency Operations Center (EOC) was located at the Surrey Operations location in Surrey, BC. The exercise was designed to simulate a field response with external partners, the Abbotsford Fire and Rescue Services, test interoperability and communications between field and EOC locations. The MS Teams platform was used to facilitate a virtual EOC with external parties and to connect various boardrooms throughout the building. Fortis uses the Incident Command System (ICS) as their management system.

Exercise attendees included Fortis staff, the CER, Abbotsford Police Department and the Abbotsford Fire Rescue Services.

The exercise met the criteria of a full-scale exercise as defined under CSA 246.2 Emergency preparedness and response for petroleum and natural gas industry systems.

 Exercise planning and conduct
Canada Energy Regulator (CER) staff contacted the Fortis exercise planner several times over phone and Teams leading up to the exercise. CER staff used these calls for introductory purposes and to describe our role in Compliance Verification Activities. Staff were provided electronic copies of the Master Sequence of Events List (MSEL), the Fortis BC Corporate Emergency Response Plan (ERP) and the Huntingdon Inc. ERP. The MSEL contained the timeline for the day and the planned injects that would be submitted during exercise play.

For the field portion, there was an exercise facilitator on site, and senior staff attended to observe and mentor newer employees. Two exercise facilitators were present in the EOC.  Weather conditions were not pre planned and instead used real time conditions.


The exercise scenario was a release of natural gas from the Fortis Huntingdon station. The release would impact a nearby home and Fortis customers and the Canada / US border crossing. During the scenario and inject was created for the SCADA system to become unavailable, possibly due to a cyber-attack on the company.

The exercise objectives, as identified below, were attainable, measurable, and realistic for the exercise. The scenario was designed in consideration of the hazards and risks posed by the Company's operations. Exercise control was sufficient for the size and scope of the exercise and appropriate injects were adequately progressed throughout the scenario.
 
ICP Objectives

 
EOC Objectives

 
Notification and Reporting
Notifications during the exercise were made to appropriate agencies and stakeholders. These included Abbotsford and Sumas Fire and Rescue Services, a landowner adjacent to the station, Emergency Management BC (EMBC), Enbridge Inc. (formerly Spectra Energy Corp), Northwest Pipeline, the Transportation Safety Board (TSB) and CER.  

Notifications were made in a timely manner and the company had the appropriate contact numbers. However, CER staff in the EOC noted inconsistencies between the Huntingdon Inc. ERP and the Corporate ERP, such as confirming what role is responsible for entering the incident report into the CER’s Online Event Reporting System (OERS). CER staff are of the view that Fortis staff would benefit from additional training and clarity on regulatory notifications to the CER. This should include reviewing the role in the response structure that would be completing these notifications and enhancing familiarity with the CER OERS to ensure Fortis staff are aware of the information required for the.
 
Safety
The field exercise began with a site safety briefing. The safety briefing was thorough and included traffic concerns, slips trips and falls, muster locations, windsock locations, and site layout and familiarization for visitors, including the fire department, who would be playing in the exercise. Weather was noted as a concern due to storms in the area. COVID-19 protocols were in place which included the availability of hand sanitizers and limiting the number of people in the on-site Incident Command Post (ICP) to four. CER staff noted that exercise players maintained proper social distancing and followed the expected provincial protocols.

When the Fortis team and the fire department were preparing to enter the site, both agencies worked well to fully understand each other’s processes for entering an active emergency site. This included hand signals for communication and the fire department’s familiarity with the general layout of the Huntingdon station. Fortis staff answered specific questions from the fire department to create the safest possible entry plan for all players. 

Both the Fire department and Fortis staff had first aid credentials in the event of onsite injuries, and BC ambulance was notified of the exercise.
 
Response Management
Fortis’ EOC stood up for this exercise and quickly staffed the relevant Incident Command System roles of EOC Director, Planning, Operations, Logistics, Liaison, Dispatch, Environment and Communications. Company personnel made good use of the tools available to them including the ERP, wall charts, visible role identification (vests), forms, and role checklists. CER staff noted that while the response was activated in accordance with the ERP, inconsistencies were noted between the ERPs and response execution. For example:

CER staff are of the view that reviewing the ERPs to ensure consistency and alignment between expected actions and associated roles and responsibilities (task lists) and providing additional training to response personnel would facilitate the execution of a safe and timely response.

CER staff in the EOC observed gas-usage considerations and advanced planning discussions that included ways to ensure continuity of gas supply (such as LNG and other suppliers), available line pack throughout the system and expected usage based on current weather compared with previous year supply requirements.  
 
Communications
Communication between the field and EOC was primarily via cell phones, including texting and sending of files through WhatsApp. Cell service was generally strong in the area and communications seemed effective. A communication challenge that was built into the exercise was the loss of SCADA communications and loss of security cameras between the Huntingdon station and the EOC, which required staff to find alternate methods to obtain observations from the field and was accomplished through greater contact between EOC and field personnel.

CER staff noted connectivity issues as screens routinely froze or the EOC was unable to hear the other rooms. Fortis staff indicated that part of these issues stemmed from a switch from a previous platform to MS Teams and did not identify connectivity concerns once the switch was complete.

In the field the entry team, made up of fire department personnel and Fortis staff, communicated verbally and with hand gestures for the entry team.

Tactical Response
Fortis staff did not enter the site initially, which was appropriate to this incident. When staff were responding to the alarm and heard the release of gas from their line, they remained at the property line and established a roadblock with their vehicle and traffic cones, as outlined in their ERP. The Fire department was notified, responded to the site, and performed initial modeling of the natural gas plume using the WISER app. Evacuation of the adjacent property was discussed, though a mock evacuation was not carried out for this exercise.  
The fire department and Fortis staff jointly planned for entry to the site for manual shutdown using the site intel gathered from the company’s EOC and the technicians on-site. Remote shut down could not be achieved as the scenario stated that the EOC lost SCADA contact with the facility. The fire department used hoses to create a hydro-curtain on the releasing gas in order to lower the chance of ignition and provide a higher level of responder safety. The positions of the hydro curtain was determined through the fire department using the WISER App which provided plume modeling. Staff instituted a check-in / check-out policy with the fire department to ensure all responders were accounted for, and fire and Fortis staff wore SCBAs (Self Contained Breathing Apparatus) to access the site. CER staff noted that the fire services and Fortis staff worked efficiently together with both sides contributing to the plan.  
The Fortis and fire department entry teams accessed the site and had manually shut-in the site within 30 minutes.
 
Environmental and Socio-economic Considerations
ICP staff took into consideration the possibility the homes or businesses in the area being without a natural gas supply due to this incident.
 
Post Exercise
At the end of the simulation, both the EOC and field staff provided thoughts as to the exercise. CER staff witnessed the strong corporate and response knowledge of key personnel within the EOC and are of the view that additional training should be conducted, leveraging these key individuals as coaches and mentors or through shadowing opportunities, to build additional response capacity.

Fortis staff stated that increasing the physical size of the EOC would be beneficial to the overall response. CER staff supported this recommendation, especially given the challenges of maintaining COVID-19 protocols in a small space, such as having to rotate staff in and out of the EOC or make use of other locations within the building. This was not conducive to a smooth integration of all required personnel and created delays in having to repeat briefing information or pull staff away from other duties to go find the required personnel for meetings.

In the field, CER staff observed that Fortis and the Abbotsford Fire and Rescue Services had a discussion around the role of on-site command for an incident and that further discussion would be held between the two agencies on that topic. CER staff offered to attend that discussion in case there would be benefit for the regulator to participate.

CER staff noted that the established objectives were met for this exercise.
 
 

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:

- 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