Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: 2193914 Canada Limited
Operating company: Enbridge Gas Distribution
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Verify response capabilities during full scale exercise conducted jointly with TransCanada (CVA 1819-271). The exercise will be conducted in Brampton, Ontario on October 16 and 17, 2018.
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: 2018-10-17 16:30
Discipline: Emergency Management
Categories:
Facility:
Observations:
On 16 and 17 October 2018, the National Energy Board (NEB) attended a full scale emergency response exercise in Mississauga (Ontario). NEB Inspection Officers were on site at the Incident Command Post (ICP) at the Holiday Inn in Mississauga as well as at the incident site on the corner of Heritage Road and Edgeware Road in Brampton (Ontario). The exercise was a requirement under the National Energy Board Onshore Pipeline Regulations (OPR). The exercise included establishment of the ICP and deployment of personnel with equipment to the incident site, and it tested the company’s ability to respond to an emergency and work effectively with first responders.Enbridge Gas Distribution (EGD) and TransCanada Pipelines Limited (TCPL) jointly planned and conducted this exercise and engaged potential exercise participants during these phases. EGD staff reached out to the NEB during the planning of this event to discuss their goals for the exercise and potential NEB participation. An exercise participant package was distributed prior to the exercise date identifying exercise objectives which were attainable, measurable and realistic for the exercise. Some of the objectives were shared by the companies, and others were specific to EGD. The exercise scenario was designed in consideration of the hazards and risks posed by the company's operations. The simulated scenario for this exercise involved a stolen bulldozer hitting a valve, causing damage to the valve, ignition of natural gas and damage to an adjacent valve, causing gas to be vented to atmosphere.The exercise occurred over a 2 day period. Day 1 included initial incident response at the incident site and company staff working at the Holiday Inn (simulating the escalation of notifications and discussions happening in both corporate offices). The exercise resumed on Day 2 with the stand-up of the ICP in Mississauga and a transfer of command. EGD also exercised its corporate EOC in North York on Day 2 of the event. NEB staff did not evaluate the response conducted in the EOC. Prior to the exercise on both days, the facilitators went over the scenario, objectives, rules of play and the need for external communications to stress that a real incident had not occurred. Site security and public safety were adequately considered at the ICP and at the incident site. At the ICP, participants checked in and wore passes on lanyards. Invited participants included 15 municipal, provincial and federal organizations and the Canadian Red Cross. The majority of these organizations attended both days of the exercise. EGD extended an offer to participants to contact their Emergency Programs Office, in person at the exercise or via email, if they are interested in Natural Gas Awareness Training or in their new Train-the-Trainer initiative, which was developed with the Ontario Association of Fire Chiefs.A pre-exercise safety orientation was conducted during the morning on Day 1 at the Holiday Inn. This included how to access first aid, site emergency procedures and situations that would result in suspension of the exercise. The orientation was comprehensive and applicable to the hazards that could be encountered throughout the exercise. This also included high level technical training addressing:
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
The exercise began with a mock 911 call. The Brampton Fire Department, Police and EMS each detailed what they would likely be doing once that call was received, and how the information obtained from the call would impact their decision to attend or not, and what level of resources they would mobilize. This was a good learning for players in the room, to get some insight into what each first responder group would likely consider in their initial actions. EGD had given a review of their Emergency Response Procedures in the morning and, upon notification of the incident in the afternoon, categorized this event as a Level 3 incident, as per their Emergency Procedures Manual.An incident name was established and external notifications to the NEB and Transportation Safety Board (TSB) were exercised as part of the scenario as per incident reporting requirements under the OPR.
Observation 3 - Safety
Safety briefings were conducted for responders and field staff and a field safety officer was assigned to the incident site. The field safety officer did enforce company PPE standards for personnel at the site and site check-in/check-out procedures were followed. Safety equipment was available and used at the incident site. This included demarcation points for zones of entry, barriers and signs. No safety equipment was required for responders in the ICP, but a safety and security briefing was conducted to highlight some hazards eg. cables for computers and other electronics, use of a cell phone while walking, stairs and food allergies. Mitigation strategies for hazards were observed to be implemented (eg. Electrical cords running along the floor were securely taped in place).
Observation 4 - Response Management
EGD uses the Incident Command System (ICS) to manage their incidents and demonstrated competence and familiarity with the ICS during the response to this simulated incident as well as effective liaison skills with stakeholders and response partners.Upon notification of the incident, an EGD employee was dispatched to the site. This person donned a green hard hat to signify that he was the IC for the company. EGD’s use of a green hardhat for their incident commander is a great adaptation of the ICS system in the field and makes it easy to identify their IC. They also use a portable “ICP box” which is a fully contained box similar to a pelican case, with extendable legs for use in the field. Once open, the box has some supplies (forms, pens markers) and a white board with permanent fields for incident information that can be used to keep track of incident assignments and resources. It also has lighting for use at night.Once on site, the EGD IC met with the municipal incident commanders (Brampton Fire, Police and EMS). After conferring with the municipal ICs, EGD spoke with the TransCanada IC and they agreed to form a Unified Command to manage the response to the incident.As the field response was evolving, other company staff were located at the Holiday Inn, simulating the escalation of response inside the company – making internal and external notifications and speaking with various agencies as new information (“injects”) came to light.Once the personnel resource needs of the incident grew, an off-site ICP was stood up. The kick-off to the work at the ICP was the transfer of command between the initial IC and the relieving IC. The information relayed to the incoming EGD IC was delivered very effectively and included all pertinent information of the response activities undertaken to that point. Subsequently, additional staff assignments were made to the Command and General Staff positions. These assignments were recorded on an ICS 207 organization chart which was posted on the wall in the ICP. For each senior role (Section Chief or Officer), there was a deputy or an assistant named from the other company (eg. TransCanada held the role of Planning Section Chief and EGD provided the Deputy Planning Section Chief). This worked well except for when meetings outside the main ICP-room were held as representatives from both companies attended the meetings leaving no deputy in the ICP to make decisions or action items to keep the response moving. If equal company representation is expected at meetings, a second Deputy Planning Section Chief should be appointed and can remain in the ICP.No GIS unit was formally stood up at the ICP. EGD staff informed the NEB that their GIS unit was available to them in Toronto to generate maps as needed, though they did not have plotter printers available, so maps printed at the ICP would be on letter sized pages only. Larger maps depicting zones of response and resource staging areas would have been helpful for the IMT staff, assisting and cooperating agencies to have a picture of the event status as it unfolded.The incident status display was well maintained once the needed information started to get generated.Span of control and chain of command appeared to be followed. It was observed that the Technical Specialist of Network Analyst in the Planning Section was generating a lot of important information (customers impacted, number of facilities impacted, area of impact, mapping etc.). Although this did not appear to have any performance impacts, it is noted that the Planning Section Chief, in addition to ensuring that the work is completed as per the Section’s responsibilities, should also monitor staff for overexertion as this could impact performance (although it did not in this case).It was noted there was a good “rainbow effect” of different colored vests interacting with other tables as the event progressed.
Observation 5 - Communications
Outside of emergency responders (fire, police, EMS), communications and coordination with municipal agencies were not as robust as they should have been at the outset of the exercise. Municipal emergency planning authorities have valuable information that can help companies design their response tactics. This resolved as the incident planning advanced throughout the second day and the agencies were invited into the Planning Meeting. It is possible that these agencies were not approached sooner by the Liaison staff in the exercise as they had registered as observers instead of participants.Working relationships built amongst responding parties and agencies and those potentially affected by an incident or those with expertise to inform the response were extremely beneficial. This was observed with the valuable information provided by the City of Brampton, City of Vaughan and the Region of Peel Emergency Management Office.The roles and responsibilities of the company versus emergency services personnel appeared to be well understood by both: this was likely facilitated by the morning safety and information session held on Day 1. A benefit to beginning the exercise in this manner meant that there could be more focus on the specifics of the simulated incident and to efficiently develop that strategies and tactics for the response. Communication and coordination between the EGD IC and other incident commanders was excellent.NEB Staff observed that the Public Information Officer (PIO) and personnel in the Joint Information Centre (JIC) were efficient in addressing communication needs for the incident. NEB Staff observed company JIC members meet with municipalities and other affected stakeholders to assess and develop a plan of approach to achieve the communications objectives for the exercise. Throughout the exercise, NEB Staff noted a well-coordinated, well-executed effort throughout the ICP and the JIC, specifically related to external communications produced and disseminated.
Observation 6 - Response Tactics
EGD conducted a tactical response in the field on Day 1 and developed response tactics for the current and next operational period during Day 2 of the exercise. Planning and Operations sections were observed to be collaborating closely on developing strategies and tactics once thy received the objectives from UC.One of the response tactics proposed by TransCanada would have had the unintended consequence of a loss of supply of natural gas to customers, including the potential loss of heat for residential customers. Through the collaborative incident management process, EGD and municipal partners heard TransCanada’s proposal and raised this issue, which TransCanada had been unaware of. This resulted in alternate response tactics being developed that met the needs of both companies and local municipalities.NAVCanada participation was a great opportunity for the company to learn about how a Notice to Airmen (NOTAM) is set, what information is required to do so and the proper channels to notify to make it happen. This request was simulated as part of the exercise as the scenario had the possibility to impact the flight path of certain aircraft into Pearson International Airport.An inject of a protestor making it into the ICP occurs, and local staff first seemed unsure of how to respond. This was a good inject, as other companies have security in / around their ICPs for this type of event and this exercise did not have an external security company hired to oversee the entrance to the ICP. In a real incident of this magnitude, consideration should be given to ensuring tighter access control to the ICP and meeting areas.For an event like this, being situated in or near a major population center, the importance of local community partners (ESS, Red Cross etc) was important, and the discussions around evacuations on a much larger scale than we typically see was very good learning.
Observation 7 - Post Exercise
Following the exercise, a debrief was held at the ICP. Forms were provided for participants and observers and completed forms were collected at the end of the exercise as people were signing out for the day. Each group within the ICP was invited to provide verbal feedback on what worked well and what areas could be improved.Unified Command was asked by the exercise facilitators whether they felt that they exercise objectives had been reached. All Unified Commanders expressed that they felt the exercise objectives were attained. Feedback was documented and EGD committed to sharing the joint post-exercise report with the exercise participants.NEB Staff are of the view that EGD appropriately implemented its emergency response plans and demonstrated its ability to respond to the scenario exercised in this activity.
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
