Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: TransCanada PipeLines Limited
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Verify response capabilities during full scale exercise in Brampton, Ontario on October 16-17, 2018. This exercise, titled Operation Interconnect, was jointly planned and executed with Enbridge Gas Distribution.
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.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. The simulated scenario for this exercise involved a stolen bulldozer hitting TransCanada’s mainline valve (MLV) causing damage to the valve, ignition of natural gas and damage to an adjacent valve, causing gas to be vented to atmosphere. TransCanada and Enbridge Gas Distribution jointly planned and conducted this exercise and engaged potential exercise participants during these phases.The exercise occurred over a 2 day period. The first day included initial incident response at the incident site and resumed on the second day with the stand-up of the ICP in Mississauga and a transfer of command. TransCanada also exercised its corporate EOC on Day 1 and their regional EOC in their Bolton office during both days. NEB staff did not evaluate the response conducted in either EOC. Prior to the exercise on both days, the facilitators 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) 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.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
Date & time of visit: 2018-10-16 18:54
The level of emergency was determined to be a Level 3 in accordance with the company's Emergency Response Plan and Incident Classification Matrix.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. TransCanada outlined their call system and how they process their internal alerts and external notifications.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.Notifications were conducted as per the Emergency Response Plan and were placed in an appropriate time. However, the online notification contained multiple time zone references within the event description (MST, MDT and EDT) which made the timeline more complicated. This was partly an artificiality of the exercise as the simulated incident occurred at 0100 EDT but exercise play occurred at 1300 EDT.
Observation 3 - Safety
Security and safety planning was a priority for TransCanada at both the ICP and at the incident site. TransCanada and EGD staff were present and actively monitoring participants and entrances at the site and at the ICP.At the ICP, the Exercise facilitator provided a thorough introduction to the Full Scale Exercise, identifying the Unified Command Section (UC and Command Staff), Operations Section, Logistics Section; Finance/Administration Section areas. The ICP “tables and meeting” areas were accessible to navigate to, providing a very conducive communication environment. No safety “tripping” issues were observed, proper and safe placement of electrical/communication cables was done.At the incident site, the Field Level Hazard Assessment (FLHA) included a Health and Safety Site Plan and addressed muster points, air traffic operations, First Aid, gas monitors, traffic and access awareness, general site hazards, wind conditions, hot zone and PPE requirements. Attendance of all participants and observers was strictly monitored. All personnel signed attendance sheets to acknowledge that they had received the FLHA. As the scenario changed throughout the exercise, the safety requirements were evaluated, and changed if required to mitigate potential safety concerns with exercise injects. During field response activities, TransCanada personnel showed familiarity with all necessary processes for safe work practices and notification procedures needed for emergency response at this valve site.
Observation 4 - Response Management
A Unified Command (UC) was established between TransCanada, EGD and the Brampton Fire Department. All four Sections (Planning, Logistics, Finance/Admin and Operations) of the ICS were staffed by Trans Canada and EGD, with other agencies engaged as required (eg Brampton Police worked in Operations). Roles were assigned early on by the company Incident Commander (IC) with clear identification of priority actions for Command and General Staff. Section Chiefs and other roles were named in the ICS 207 organization chart.An incident briefing was conducted by the initial TransCanada IC using the ICS 201 Incident Briefing form and command was transferred to the incoming TransCanada IC. Other members of UC were identified and introduced including EGD and the Brampton Fire Department. Appropriate objectives and priorities were developed by UC in a collaborative and consensual manner. Meetings such as UC, Tactics and Planning were run efficiently; written agendas were used, roll call was taken and meeting rules were communicated. At the meetings, a clear linkage was provided between the work to be undertaken and the objectives established within an operational period. NEB staff note that visual representation of the objectives and tactics/strategies used to achieve the objectives would have benefitted the meeting. 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 participants in the ICP and on the status board. These ongoing status updates were beneficial for responders arriving on site as they did not have to wait for the next briefing meeting to obtain information on the incident. Wall charts, wall maps and a digital mapping system and posters were effectively used.A list of environmentally-sensitive receptors at risk was created and mitigation proposed to protect those receptors. An existing GIS database was used to support this work. This activity was documented using an ICS 232 form – Resources at Risk. The GIS unit also printed maps with updated information and visual representation, as the exercise progressed.All members of UC stressed the need for an integrated response that includes all key players with response roles. The incident management team addressed the exercise inputs efficiently through open dialogue at meetings and by the responsive development of new plans as required. NEB Staff are of the view that this was a very positive outcome of the exercise and demonstrates the recognition amongst the players of the need for appropriate collaboration and cooperation during a response as part of the broader “EM system.”While the UC players and Section Chiefs were in meetings, both the Operations Section Chief (Enbridge employee) and Deputy Section Chief (TransCanada employee) were participating in those meetings. It would benefit an incident if the Deputy Operations Section Chief was available (to fulfill the role of the Operations Section Chief) to General Staff during these meetings in the event items need to be actioned such as updates, approval for plans and answering questions regarding resources and tactics. If equal company representation is expected at meetings, an second Deputy Operations Section Chief should be appointed and can remain in the ICP.NEB Staff noted that the flow of the exercise followed the appropriate steps of the Planning “P” and execution of the ICS. The ICS was fully implemented and TransCanada demonstrated a thorough internal knowledge of ICS and also had access to on-site coaches with expertise in ICS. The Planning Section Chief and Situation Unit Leader should be commended for their conduct in these positions.
Observation 5 - Communications
Overall, NEB Staff noted that communication with the Operations and Planning Sections was good.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 in the exercise as they had registered as observers instead of participants.With UC established, and in order to meet the exercise objectives, 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 the JIC working collaboratively with each other and with other agencies and municipalities at the ICP.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.Company personnel adequately prioritized internal communications ensuring all affected stakeholders were informed, demonstrating appropriate responsiveness relative to the scenario. The company’s efforts to promote collaboration among all agencies and support those involved in the JIC, positively contributed to the overall success of this exercise and its communications activities. However, the PIO did note that it was difficult to get approval of key messaging by UC in order to ensure it reflected all positions and to determine critical information to be communicated externally.
Observation 6 - Response Tactics
Tactical response occurred over the two days of the exercise. On Day 1, TransCanada and EGD initial Incident Commanders went to the municipal mobile command post near the incident site to discuss strategies and tactics with municipal first responders (fire, police and EMS). On Day 2, tactics and strategies were discussed among Operations and Planning staff and presented to UC for comment. UC appropriately discussed objectives for the response and altered them as new information became available. During this process, UC specifically emphasized the following in addition to the initial response objectives on the ICS 201 form:
Observation 7 - Post Exercise
Following the exercise, a debrief was held at the ICP. Exercise participants provided feedback on what worked well and identified areas for improvement. 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 TransCanada committed to sharing the joint post-exercise report with the exercise participants.NEB Staff are of the view that TransCanada 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
