Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Genesis Pipeline (Canada) Ltd.
Operating company: Nova Chemicals
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
This multi-agency emergency response exercise focused on a field response to a report and subsequent detonation of a suspicious package at Nova Chemicals' Lasalle Pipeline Compound.
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: 2016-10-06 14:30
Discipline: Emergency Management
Categories:
Facility:
Observations:
The exercise participant package was provided well in advance of the exercise (August 29, 2016). The package addressed the scope of the exercise, exercise participants, the scenario, event objectives, the exercise schedule and rules of play. A map of the location for the field component of the exercise was provided as was a contingency plan for weather, heat stress and actions to take in the event of an actual emergency.The company indicated that it provided advance notice of the exercise to appropriate parties: this included notifying neighbours (through mailings) and the broader public (through local media).The exercise was conducted in two phases: Phase I consisted of the discovery of a suspicious package at the Lasalle Pipeline Compound and the intitial assessment activities. Phase II consisted of incident escalation, including package detonation, which resulted in a breach of Line 16. The field exercise was held at the LaSalle Pipeline compound, which is adjacent to LaSalle Line. Two fire trucks and the fire department's mobile incident command post were mobilized to the site. The company placed signs at the side of the road to identify to the public that an exercise was underway. Participants in the field exercise were Nova Chemicals and St. Clair Township Fire Department personnel, with facilitation by the Nova Emergency Response Specialist for both phases. Additional participants were present in the Fire Department's mobile incident command post. These observers included neighbouring companies that would be affected by the incident (Shell Manufacturing and Enbridge), Aamjiwnaang First Nation and the NEB. NEB explained what its role would be in the context of this exercise and what activities that it would be undertaking. Other representatives provided information to those in command and posed questions based on their jurisdiction / area of interest. Although the exchange resulted in the ICP component of the exercise blending into functional from purely operational, participants agreed that it was beneficial to have the oppportunity to share information and ask questions.
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
Date & time of visit: 2016-10-06 10:30
One of the exercise objectives was Initial Notification. Phase I of the exercise - Suspicious PackageThe company's Pipeline Day Technician went through the actions that he would take upon discovery of the package including notifications as per their Pipeline Emergency Response Team manual. Notifications included:
Observation 3 - Safety
Date & time of visit: 2016-10-06 12:00
Although a written safety plan was not created for this exercise, the unified command (company and fire department) did identify the hazards and mitgation measures that would be taken to control the hazards for the responders and the public. Phase I Isolation of the area and shut down of the lines in proximity to the suspicious package. The isolation zone was determined in accordance with the Pipeline Emergency Response Manual. Unified Command declared that no entry is permitted in the hot zone until the package is assessed by the OPP Bomb Squad (ETA one hour as the closest team is based in London). The company also indicated that in the event of an actual incident, the railway directly west of the exercise site would be temporarily shut down.Phase II Breach of Line 16 and the released product catches on fire. The IC immediately increased the hot zone of incident. He also instructed additional safety measures such as vapour monitoring (for any product not consumed by the fire) and water monitoring (for cooling water runoff).
Observation 4 - Response Management
Nova Chemicals uses the Incident Management System for management of emergencies at its facilities. This is the same system used by the Province of Ontario. Company players in the Incident Command Post (ICP) used the Pipeline Emergency Response Team Manual and their emergency response training to guide their actions. Given the nature and duration of the exercise, assignments beyond Incident Command, Operations and PIO were not made. A Safety Officer was not identified, but safety requirements and precautions were discussed. The chain of command was followed and was consistent with the company's response structure. Vests were used in the ICP but not in the field (consistent with operational practices).Given the public safety concerns, the initial ICP was set up in the Fire Department's mobile ICP, as the fire department would be one of the first responders on scene. Since this was intended to be a field exercise, EOC activity was simulated and information relayed to the company IC. Note: the PIO would be located in the company EOC during the initial stages of the response.The company did form a unified command with the fire department for the exercise. The fire department and the company IC were very familiar with each other's roles and responsibilities and worked cooperatively to develop the response action plan. It was noted that the OPP would be the lead for this as the cause of the incident is related to criminal activity. The OPP was invited, but unable to attend the exercise. In their absence, the unified command were aware of the initital actions that the OPP would take for this scenario (eg. setting up road blocks, tasking bomb squad from London).Incident objectives were established, but not documented. As noted in observations in exercise conduct, this is believed to be an artificiality of the exercise considering that exercise observers were engaging in discussion with the players in the ICP. This prohibited the players in the ICP from functionally playing their role in the response.Response priorities were established and appropriate (safety and health of responders and the public, protection of infrastructure and minimizing impacts to the environment).No situation status displays were used in the ICP, although maps were created and shared during the pre-exercise briefing (opening meeting). The mobile ICP has an external videocamera which was trained on the field response. Video was live streamed directly inside the ICP. Notification of neighbours and communities was discussed and it was noted that this incident would impact three municpal EOCs.
Observation 5 - Communications
External Communications Initial communications to affected neighbours (landowners and companies) would occur immediately once the isolation zone for the potential incident was determined.The issuance of CVECO codes would immediately notify members of the CVECO organization of what action needed to be taken. This is a well-validated tool for inter-company and first responder communications that has been proven with several events that have occured in this region.A company Public Information Officer was observing at the mobile Incident Command Post. She described what actions and messages that the company would deliver in the first hour of the incident (for each Phase I and Phase II). In these early stages of the incident, basic facts would be shared immediately as the first concern is safety of the responders and the public. The general public is notified when CVECO codes are issued (via local radio and through the myCNN service).Internal CommunicationsRadios were used to communicate between the field and the ICP. There were some incompatibities with radio frequencies.
Observation 6 - Response Tactics
Phase IThe company took actions to secure the site and notified personnel to evacuate the immediate area. Through CVECO, the police would have been engaged and would have come in to block the main road access to the site, followed by blocking any interconnecting roads. As the pipelines running through the compound are shut down, there are other actions that would need to occur in the plant (secondary effects).It was noted that additional staff would have to be brought in to do some of the ancillary work as some operators were tasked with the response activity.Phase IIThe company identified that they would be assessing direct impacts (rupture of Line 16) and secondary impacts (potential weakening of other structures or neighbouring pipelines) from the blast.Fire Department would bring in a truck to cool surrounding assets, they likely would not attempt to extinguish the fire from the explosion on the pipeline as the gas is easier to manage while on fire than venting to atmosphere. There was little discussion on effects to powerlines and to the CSX railway that passes about 100m west of the pipeline compound.
Observation 7 - Post Exercise
Exercise participants and observers returned to the St. Clair Township Fire Hall for the post exercise meeting (debrief).The company's Emergency Response Specialist facilitated the debrief session. All attendees were invited to contribute to the after exercise discussion, to highlight best practices and opportunities for improvement. The company committed to assessing and, where appropriate, incorporating the improvement feedback into their response plans and procedures. Considerations included:
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
