Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Pembina Energy Services Inc.
Operating company: Pembina Energy Services Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
The purpose of the exercise is to provide a training opportunity for Pembina Fort St. John personnel, allowing participants to practice emergency management elements and potential response actions related to an HVP incident within an office setting. Personnel and equipment will not be deployed during this exercise. The specific objectives of the exercise are to: 1. Identify and practice internal incident reporting and call down procedures. 2. Fill the appropriate ICS roles and become familiar with role specific tasks. 3. Determine the level of emergency. 4. Conduct a Briefing Session. 5. Identify the appropriate communications plan, addressing public protection measures and notifications, government reporting requirements, and media communications.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Exercise Planning and Conduct
Date & time of visit: 2017-09-12 09:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
An exercise participant package was distributed prior to the exercise date identifying exercise objectives which were attainable, measurable and realistic for the exercise. The exercise scenario was designed in consideration of the hazards and risks posed by the company's operations and the scenario adequately tested the company's ability to respond to an incident. The facilitator went over the scenario, objectives and, rules of play (e.g. exercise duration, exercise artificialities, simulation, injects, participant roles, when to call the exercise over, how to stop the exercise in the event of a real emergency). Pre-exercise activities also included a review of the Pembina NE BC HVP ERP. The following topics were discussed:a. Objectives for the exercise;b. ERP updates and new material in the ERP (location of additional equipment caches);c. Differences in content between Corporate ERP and Site Specific ERPs;d. Discussed checklists for ICS roles and content of ICS section within the ERP;e. Discussed ICS forms and Pembina incident forms;f. Site-specific ERPs overview, area contacts, maps, equipment listing and area stakeholders;g. Incident call down and notification lists;h. Role of the Sherwood, AB Call Centre;i. Role of and support from Pembina personnel in Calgary – for example, they are able to conduct modeling tasks;j. Response priorities and incident objectives;k. Tools for various roles with the ICS – Incident commander, PIO, logistics section, planning section, Finance/administration and operations; andl. Status summary board. At the ICP, attendance of all staff was monitored and a sign-in/sign-out sheet was utilized for tracking purposes. The Incident Commander provided a briefing of the sequence of events for the incident scenario and information on the following:a. ESD Valve closed at Sweet Water;b. Lower pressure and drain line;c. Nearest check valve and block valve identified;d. Nearest residences;e. Manual closure of valves initiated;f. Air monitoring initiated, benzene, LELs and H2S;g. EPZ for ethane was used as this is considered a worst case scenario;h. SDS for ethane available;i. Staging area;j. NOTAM;k. Volume release; andl. Personal gas monitors.
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
The level of emergency was determined to be a Level 3 in accordance with the company's Emergency Response Plan and the BCOGC Incident Classification Matrix. An incident name was also established and external notifications such as those typically made to the NEB and Transportation Safety Board (TSB) were exercised as part of the scenario (the Transportation Safety Board was notified which in turn notified the National Energy Board of the mock incident). Notifications were conducted as per the Emergency Response Plan and were placed in an appropriate time. The Liaison Officer reviewed the notification list as required for a Level 3 incident as per the List of Government Notifications and the British Columbia Government Contacts Matrix.
Observation 3 - Safety
While the product released was not initially known, the response was assumed to be for ethane, which is the worst case scenario for the products transported in the pipeline. The hazards at the incident site (e.g. water hazard as swamp) and the location of incident were identified quickly. Communication with control centre was effective. A site safety plan (ICS 208 form) was developed and the SDS was available for ethane. The site safety plan included appropriate PPE and gas monitoring; behavior of released gas (staying up wind and up hill); ignition sources; and road block set up. Field personnel were told to maintain distance from the established hot zone. NEB staff observed a discrepancy/misunderstanding between Pembina personnel as to whether the product was toxic or not which impacted the Liaison Officer’s ability to answer questions he was being asked.
Observation 4 - Response Management
ICS roles were quickly filled and the organization chart (ICS 207) completed – including IC, safety, planning and operations. The role of a scribe was also assigned. ICS vests were being used. A safety watch was assigned, road block supervisor was also assigned and an incident name given. Digital maps were created quickly with pertinent information such nearest residences, location of staging area and existing facilities. An easel was also used by the scribe to take notes for participants to peruse as they needed. An Incident Status Board was present in the ICP and was updated throughout the exercise. Ongoing status updates were also verbally communicated to exercise participants in ICP. Efficient and effective discussion was observed, specifically between simulated field personnel and ICP. The Emergency Planning Zone (900m) was discussed and considered for the scenario. Pembina personnel called the emergency response companies that they would use in a real incident to determine depth and timing of resources.Incident Initial Priorities (Life safety, protection of people and protection of the environment) were displayed on the wall for participants to see. However, NEB staff did not see an ICS 202 form completed with objectives clearly identified for the scenario. In future exercises, Pembina should consider additional instruction in the use of ICS language, formalized documentation of incident objectives and priorities, and the application of ICS forms etc. to allow its personnel to become more familiar with the system for use in real life incidents. While the majority of Pembina personnel referred to ICS roles and responsibilities checklist for each respective role, not all Pembina personnel did.The main ICS forms were used as needed, such as the ICS 201 Incident Briefing form and ICS 214 Individual Log form. Ongoing status updates were verbally communicated (during briefing meetings) to exercise participants in the ICP and on the status board which is beneficial for those responders arriving on site not having to wait for the next briefing meeting to obtain information on the incident. Maps were available and used to established the 900m Emergency Planning Zone (EPZ). The EPZ was maintained until more information was known. Wall charts and posters were effectively used - they included: List of Government Notifications; British Columbia Government Contracts Matrix; British Columbia External Agency Notification and Level Designation Log; Event Status Summary Board; BCOGC Incident Classification and Resource Inventory Table and Status Chart. A wall map for unified command meetings would have been beneficial. As a member of Unified Command, NEB was satisfied with conduct and thoroughness of meeting and that a scribe was available to take notes. NEB staff note that the meetings did not have written agendas, roll call was not taken, meeting rules were not communicated and there was no clear linkage between the work intended to meet the objectives established within an operational period. NEB staff noted that the flow of the exercise did follow the appropriate steps of the Planning “P” and execution of implementing the ICS.
Observation 5 - Communications
Meetings were routinely held and the incident status board was updated where possible. It was recognized by some sections that the status board could’ve been updated in a more timely fashion but given the time frame of the exercise and how quickly things progressed, this was challenging at times. It appeared that communication flowed well. Incident Commander communicated steps in the response process and simulated field staff was informed continuously. Ongoing status updates were communicated to staff present at the ICP. NEB staff were satisfied that Pembina demonstrated that the company can respond appropriately and communicate with potentially affected parties for the scenario tested. NEB staff did not observe that media briefings and media lines were developed for the incident. A reminder to Pembina that in a real incident, the NEB and other agencies in Unified Command should have the opportunity to review the media briefings and lines prior to the correspondence being finalized.
Observation 6 - Response Tactics and Post Exercise
Hazard monitoring was considered and conducted. Gas monitors were in use at the incident site, with readings simulated and regularly taken. The Pembina NE BC HVP ERP was referred to throughout the exercise and verification of appropriate procedures was continually double checked. Pembina had an incident command system in place and demonstrated knowledge and training in the command system, however, it would benefit the company to provide additional training in ICS for Pembina personnel. An Incident Command Post (ICP) was activated and was consistent in size with the company response.NEB general observations were that participants at the exercise understood their roles and were aware of the areas they could improve on within their role. Liaising and cooperation between participants in the ICP was satisfactory and the overall flow of the exercise improved as the exercise progressed. The incident management team addressed the exercise inputs efficiently through open dialogue and by following instruction and procedures as required. NEB staff noted that ‘Input 10’ (The response Branch Director reports that an ignition source has ignited the vapour cloud ) was not executed and that Pembina should consider this input for the next exercise to make the scenario more challenging. NEB staff noted that Pembina response personnel became more familiar and comfortable with their various roles as the exercise progressed. Overall, the exercise was successful in achieving the exercise objectives. A debrief was conducted at end of the exercise. All participants were able to verbally provide feedback in a round-table setting. Participants discussed what they saw worked well during the exercise and also what areas of improvements were needed. Generally, participants felt that communication between groups improved and they felt better prepared to participate in an actual response if required. The feedback was documented by Pembina. The following, but not all, general highlights were noted by NEB staff:Exercise participants used ICS forms and were requested to leave all documents in the ICP for collection by Pembina. What worked wella. EPZ and worst case scenario product release was informing the response;b. Roles were quickly assigned and those assigned were comfortable in the roles;c. Pembina personnel used the ICS 214a Individual Log very well; d. Electronic maps updated constantly;e. Location of personnel, public inventory, incident issues board was consistently up to date;f. OPS Section updating maps was excellent, staging area location was identified quickly, roles were assigned quickly and level of emergency was efficiently determined; andg. Pembina personnel were collaborating and talking through the steps to take to in order to adequately respond to a real life incident. Areas for improvementa. Wall maps in the Unified command and at the ICP were needed;b. Table flags (e.g. identifying Ops Section, Planning Section, Logistics Section etc.,) for each ICS section would be beneficial in maintaining span of control, chain of command and to ensure that dissemination of information flows from Pembina personnel to the appropriate Section Chief (or Deputy) and then to UC; c. The NEB encourages Pembina to consistently implement ICS documentation protocols as a tool to increase response efficacy in an actual emergency situation; d. Briefing meeting checklists need to be followed such as role call, meeting rules, and written agendas, as well as systematically go through priorities/objectives and work needed to accomplish these. It would benefit Pembina personnel to consistently refer to ICS roles and responsibilities checklists and ICS forms. For example, Logistics seemed to be taking a number of resource requests verbally – using the forms allows for better tracking and ensuring that all requests were actioned and executed;e. PIO could have provided more detail on communication plan and content of media release;f. Communication via chain of command, service listings, being precise on resources, designation of deputies and help for Section Chiefs and Liaison Officer;g. Clarity is needed for the NOTAM (i.e., whose responsible and what information do they need in order to complete the notification; andh. While the Incident Status Board contained relevant information, it didn’t contain all information. A more formal plan for the type and detail of information being displayed would be beneficial. For example, although nearest residences were highlighted on the electronic map, more detailed information on residences/landowners was not available and while facilities were also highlighted on the electronic map, information highlighting the existence of another operator (Penn West well site west of the incident site) was not available or communicated clearly.
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
