Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: NGTL
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
An exercise evaluation was identified as part of the NEB’s annual compliance plan, to verify response capabilities as per Clause 10.5.2.4 of the Canadian Standards Association (CSA) Z662-15. The exercise scenario was a gas line rupture that occurred on the NPS 36 Western Alberta Mainline south of Cochrane, AB on March 28th at 7:32 AM. Technicians were dispatched and confirmed an ignited rupture and began working with RCMP and fire departments to secure the area and establish command. The exercise objectives were to reinforce ICS principles and rules through exercise introduction, observation and coaching; to complete an ICS 201 form and transfer command; to familiarize participants with Rocky Mountain Region's emergency response trailer; to establish an incident command post (ICP) with unified command; to actively manage the ICP situation boards; to compile a complete or partial incident action plan (IAP); and establish a regional emergency operations center (EOC). Several local First Responders were invited to participate in the exercise.
Compliance tool(s) used:
Facilities:
Facility Types
Regulatory requirements that apply to this activity:
Observation 1 - Exercise planning and conduct
Date & time of visit: 2018-03-27 13:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
The pre-exercise meeting and training commenced at 13:00 at the Cochrane Lion's Club Event Centre in Cochrane, Alberta. A safety briefing was given and a participant package was distributed. The scenario was read through as a group and the exercise ground rules were reviewed.The scenario design was based on a gas line rupture occurring and a local landowner contacting the TransCanada emergency line to report the rupture. A NGTL technician was dispatched along with the local fire department and RCMP to secure the area, establish command, and ensure no one was injured. An Incident Command Post (ICP) was established.The participant package included site-specific maps and photos of the facilities involved. A pre-drafted job safety analysis (JSA) for the exercise incident was reviewed with the entire group, communicated as a living document, and signed by all observers and participants on both days of the exercise. The JSA was thorough and encompassed the activites to take place at both the ICP and field site. It also took into consideration changes in conditions (weather) and locations.For safety considerations and implementation of the company back-in policy, staff wearing high visibility vests were available in the parking lot to guide drivers backing into their slips. There was sufficient staff to ensure this progressed safely.The incident site was visited by all participants, transported by buses, at 7:30 AM the day of the exercise to watch as the exercise began. The location of the site was suffiencent size to safely contain the vehicles (buses; fire trucks) and allow for movement of personnel. Due to the cold, the school buses used for transportation were directed to stay at the site of the field portion of the exercise so they could be used as shelter if needed.After visiting the site and touring the Rocky Mountain Region's emergency response trailer, response staff returned to the event centre where an ICP was established and the exercise timeline was restarted to be the start of day 2 of the incident response. Numerous external agencies and organizations were involved in the exercise. Interaction and discussion among the agencies and organization was good and collaborative. The company provided trainers to help establish and implement an effective process to ensure company personnel were trained and competent to perform their duties. The trainers were working with participating personnel to ensure they were aware of their responsibilities in relation to the processes and procedures required to meet the exercise and incident goals and objectives.NEB staff are of the view that the exercise design considered potential hazards related to TransCanada's operations however the exercise did not allow enough time to fully engage in the ICS process, roles and ICP functions. The timeline restart to begin working as if on day 2 of the incident would have been more effective if more clarity of what happened on "day 1" was provided as a starting reference. A Master Sequence of Events List could be considered for future exercises to aid in focusing the work of the incident management team.
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
Date & time of visit: 2018-03-28 08:00
The notification process occurred as follows:Upon receiving a phone call from the local landowner to the TransCanada emeregency line, Gas Control dispatched an on-call technician to the site to verfiy the incident. Once the incident was confirmed by the technician, he became known as the company first responder (staff member first on site of the incident) and began notifying company staff as soon as possible while fire officials responded and established an Incident Command Post at a safe distance to the incident in their mobile command centre. The company first responder made notifications and reported the incident as per the comapny emergency response plan (ERP), which included notifying the National Energy Board.Once an incident was confirmed, the first responder and arriving company staff conducted a risk and hazard assessment as per the ERP and classified the incident as a level 2 incident. The location of the incident engaged two different fire departments, Cochrane and Rocky View, who established unified command at the site.
Observation 3 - Safety
Date & time of visit: 2018-03-28 07:00
Safety began with the detailed job safety analysis (JSA) and all responding personnel signing onto it upon arrival at the field site or ICP. The mock release enabled workers and fire departments to consider additional hazards at the site and demonstrate due care and attention relating to electrical hazards, material ejected from the rupture location, and local traffic.Appropriate PPE was used by direct participants (those demonstrating a role in the incident). Personal gas monitors were used to detect any vapours at the staging area. An 800m safety zone is standard practice for responding to a leak/ignition. The Fire department had its own personnel tracking process and followed it while at the incident site.The ICP was set up with safety considered, such as power cords secured to the floor. A tag system was in use for anyone entering the ICP. This is an effective means of tracking personnel in the ICP.The roles of Safety Officer and Assistant Safety Officer were filled by personnel attempting these roles for their first time. Coaches were avaialable to provide guidance.
Observation 4 - Response Management
The Incident Command System (ICS) was used for the response to the incident. The company operator dispatched to the incident site confirmed and reported the incident to his supervisor and then became known as the company first responder. The local fire departments responded as well and established a unified command between Cochrane Fire Department and Rocky View Fire Department.Once the incident was confirmed, the ERP was activated and the company staff began establishing an Incident Command Post (ICP) at the Lion's Event Centre in Cochrane and a regional emergency operations center (EOC) in Airdrie.At the ICP, a company Incident Commander was appointed and established unified command with the National Energy Board and both fire departments. Additional company personnel were assigned roles in the incident management team considering their company position and training. They fulfilled their role-specific responsibilities and utilize the company ERP and training tools.The ICP was established quickly and staffed for training purposes. The span of control was maintained throughout the incident at site level and ICP level, and chain of command was displayed at the incident site on the Unified Command trailer's display board as well as at the ICP on the incident status board. The response structure followed the company ERP guidelines and staff were familiar with the structure. Staff gave feedback requesting more role-specific ICS training and more time to engage in their roles.Incident response priorities and objectives were discussed and with some coaching, appropriately developed. These priorities and objectives were further defined and displayed as the response progressed. Considerations for staff and public safety, containment and environmental protection were discussed and planned for. The potential for the incident to escalate was also discussed from both a safety and emergency response perspective.Maps were displayed in the ICP to show the site location and layout. Modeling was not undertaken due to the scale and short-lived nature of the incident; the ERP does contain worse case modeling and determined emergency response zones of 800m either side of the line for this system.
Observation 5 - Communications
The communications group was well staffed with certain staff dedicated to handle media inquiries, and other staff focused on developing products and messages.The Public Information and Liaison Officers functions were well-coordinated. The knowledge gatherers, Liaison Officers (LO) and Public Information Officer (PIO) frequently shared information and updates with other ICP members and agencies to help inform message development and media responses. The PIO and Liaison officers had trainers supporting them to assist with knowledge transfer and coordination of activities.An external communication strategy was formulated with messages prepared for affected persons, the public and media. PIO had established appropriate tactics that demonstrated that the company can respond appropriately and communicate with the public and other potentially affected parties for the scenario tested. The communications methods, objectives and response priorities established by the PIO were appropriate for the scenario.Communications personnel made good use of the knowledge of stakeholders and residents in the area to inform their approach. They addressed the public's need for information through the establishment of a public information line and a town hall. The group also made good use of social media to provide timely information to the public.Communications personnel were actively involved in the incident command briefings and meetings where they spoke to their completed and upcoming tasks. Exercise inputs and key information were discussed and disseminated amoung ICP staff and relayed to the public during media briefings. Meetings and information sharing was frequent, all participants understood their respective roles and how to action requests.NGTL communications personnel became more familiar and comfortable with their various roles in the ICS structure as the day progressed. Relationships built amongst responding parties and agencies were extremely beneficial. Liaising and cooperation between sections was well done. Additional and more detailed situation reports and updates to the ICP would be helpful to assist players’ understanding the current status of the situation, particularly in the day after the incident. It was at times difficult to determine the timeline for response events due to the lack of clarity regarding which response actions had occurred on day 1 of the incident.
Observation 6 - Response Tactics
The site of the incident was located on a right of way with 4 pipelines running through it, a power line running above it and a fibre optic line along side it. It was located to the south of Cochrane, up hill in a large open field surrounded by homes, a power facility, and some forested land. The wind was blowing SE to NW and it was -30C for the exercise.A company operator was dispatched to site to confirm if there was an incident. He confirmed that there was an incident and began notifications to company superiors as per the ERP; the operator then assumed the role of company first responder.The company first responder stopped approximately 800m from the site (for the exercise, it was closer to 300 m away from the site) and established a staging area, as per ERP protocol.Fire fighters from both Rocky View County and Cochrane Fire Departments were dispatched and arrived at the site staging area; the rupture site was in Rocky View County but reached first by Cochrane fire. RCMP also responded and were used to establish road blocks around the site. RCMP and Fire also undertook evacuations of those within 800m of the site.Upon notification of an incident from the company first responder, the control center shut in the closest valves for the pipeline upstream and downstream to isolate the section. Company staff were dispatched to the field to verify the valves were closed. Closing the valves reduced the hazards posed by the ignited gas. However, burn down would take several hours. Fortis was notified and dispatched by the fire departments to cut power to the power line that had been burned and had fallen to the ground. AltaLink was established as the owner of the power lines and power facility that was impacted and was notified.The fire departments created a Unified Command and established an Incident Command Post in a mobile trailer they brought to the site staging area. The potential for the situation to escalate, vapours to change course, and further evacuations to be required were considered between unified command and the company first responder.After notifications were made, the company established an ICP in Cochrane. The company safety officer at the ICP considered the hazards posed by pieces of the pipeline that had been ejected from the site and established a protocol of treating any pieces found as contaminated, not to be touched by anyone and a hot zone to be established around each one.Evacuees were welcomed to the town-established reception centre where the company eventually established an information booth staffed by company personnel who could provide incident information.A creek was identified as a potential environmental receptor and assessed for impacts and potential impacts of response tactics.
Observation 7 - Post Exercise
Date & time of visit: 2018-03-28 15:00
After the exercise was finished, a debriefing meeting to discuss the learnings from the exercise was held. Positive learnings from the exercise included the following:- there were lots of good coaching opportunities throughout the exercise and coaches were provided for each ICS section- NGTL role-specific booklets were used and a helpful guidance tool; the booklets provided are also available as an app for company staff.- the company's Regional Emergency Operations Centre was activated and actively reached out to section chiefs in the ICP to offer help and resources.- there was good communication within the ICP and amoung response staff.- there was great fire department and NEB participation, which provided opportunties to learn more about what they do, what roles they fill and what resources they can offer.- coaches were appropriately used when the management of the response was not focused or following ICS procedures. For example, coaches suggested restarting the objectives meeting to ensure that it followed ICS procedures.- there was excellent recognition of the potential for inherent hazards posed by piece of the pipeline thrown from the site. For example, the safety officer decided to create hot zones around all peices of pipeline located on and off site.
Areas for improvements noted during the exericse included the following:- more time was needed by everyone to get into their response roles and start understanding the ICS process, be able to use the forms, communicate between sections and allow the response to evolve.- there was a need for more clarity on the previous day's response activities, objectives, and progress. Entering an exercise as if on "day 2" of the incident was confusing as the timeline of response events and actions was not completely clear.- There were requests for additional ICS training to prepare for exercises and incidents and be comfortable in roles and responsibilities.- there were a couple different versions of ICS forms in use; staff noted the need to pick and stick to using only one version of the ICS forms.- meetings needed to be more controlled for attendance and purpose; it would be beneficial to have a meeting schedule, attendance list, and designated meeting area. - there needed to be a designated spot on the incident status display for a meeting schedule- audio equipment would be beneficial to be able to hear people speaking during meetings - NGTL guidance booklets should include meeting descriptions and list of attendees- the exercise overall was rushed, which took away from learning opportunities and caused confusion and more need for coaching than potentially needed.- the fire departments noted the need fo additional discussions with NGTL on how tactical field response plans can better inform their municipal response plans. Fire departments also noted that once the incident is no longer a threat to the public, they would better serve as technical experts rather than as part of unified command.All exercise documentation and feedback forms were collected from participants to be filed and reviewed by the NGTL emergency program staff.NEB staff are of the view that the exercise objectives were met. Areas specifically recommended for improvement include:- providing more time for the creation of a useful incident action plan- improving upon the lack of clarity surrounding the response actions stretching from the time the incident occurred to the starting time of the exercise. A clear timeline of response events should be established and provided when using a time lapse for an exercise.- NGTL should consider the potential for confusion by referring to their personnel as First Responders. This term is typically used for police, fire, and EMS and board staff are of the view that it should be reserve for these agencies exclusively, to maintain clarity of agencies responding and agencies on site.
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