Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Kinder Morgan Cochin ULC
Operating company: Kinder Morgan Cochin ULC (Cochin)
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Tabletop exercise which included a boom deployment drill. The exercise commenced at 09:00 on September 14th, 2016 at the Incident Command Post (ICP). The ICP was located at the Civic Centre in the Town of Outlook, Saskatchewan. The boom deployment was conducted by Clean Harbors, as contracted for in the Cochin EPM.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Section A - Exercise Planning and Conduct
Date & time of visit: 2016-09-14 09:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
There was an exercise participant package distributed prior to the start of the exercise. The opening meeting went over this package and highlighted objectives of the exercise. Staff note that the exercise objectives were quite ambitous and not likely attainable considering the length of the exercise. Specifically, the objective to complete an Incident Action Plan would not likely be attainable in the time frame of this particular exercise.The exercise facilitators discussed all of the exercise objectives, rules and the scenario. The scenario involved a third party contractor damaging a condensate pipeline, resulting in a release of product and product flowing overland into the South Saskatchewan River. This particular scenario was plausible. The scenario briefing was somewhat too brief and more time could have been spent reviewing the 201 Incident form. The number of Cochin staff attending the exercise was also realistic in that they would be available in the area and able to respond.There were no site security or public safety concerns at the exercise location, and there was an identified first aider on site as well as easy access to the hospital which was adjacent the building. The facilitator went over any site hazards, mitigation measures and PPE requirements. The field component of the exercise was limited from the original scope due to low water levels in the river and contractor availability. There was a check-in/check-out form at the entrance to the building to maintain accountability throughout the exercise.Section 3.5 of CV1516-427, NEB Emergency Response Exercise Evaluation of Cochin's exercise in Regina, Saskatchewan on September 23, 2015 noted that NEB staff did not observe any form of signage indicating a drill or exercise was in progress for the information of local citizens or other interested parties. During this exercise, NEB staff observed Cochin staff providing and directing the use of placards noting "Kinder Morgan Drill in Progress" for placement at the ICP (Civic Centre) and the incident site during the boom deployment drill. This is an observed improvement.
Compliance tool used: No compliance tool used
Observation 2 - Section B - Exercise in play
The exercise level was declared during the initial Emergency Response Line (ERL) call made at 09:27 and the Transportation Safety Board (TSB) was notified during this same call, as per their ERP protocol. The company also reported the incident on the NEB website and NEB staff on site recieved the notification under an hour after the incident occured. Staff note that as the exercise was called-in to the TSB, it is not necessary to also report it on the NEB's Online Event Reporting System.
Observation 3 - Response Management
The company staff used their EPM to guide them throughout the exercise and used this tool effectively. Cochin uses ICS and the staff were trained in their roles and responsibilities; in order to further their training, a few Cochin staff were assigned new ICS roles from what they had been assigned in past exercises. The ICP was selected quickly and appropriately located to be near to the incident site. ICS roles were also assigned quickly and appropriate span of control was maintained throughout the exercise. The chain of command was maintained according to ICS structure; a few exercise pauses were taken for the exercise facilitators and senior company staff to provide high level updates, coaching and guidance for all exercise participants, particularly focusing on those Cochin staff that were new to their assigned ICS roles. Staff note that these pauses were effective for training purposes.The incident objectives (initially) were:1. maintain safety of the public and responders and company staff;2. minimize product release;3. make notifications to proper authorities; and4. establish an ICP. These changed as appropriate as the exercise evolved. Response priorities were people, environment, assets, and reputation, in that order.NEB staff did note a need for the company to better define and clarify the differences between the incident objectives, strategies, and tactics throughout the exercise.Objectives and initial actions were appropriate and consistent with the Cochin OSRP [ERP]; however, more explicit use of Cochin's own "Initial Response Actions" (p. 3-3, Cochin Pipeline OSRP) and "Specific Incident Response Checklist for Line Break or Leak" (pp. 3-6 and 3-7, Cochin Pipeline OSRP) may assist in guiding the Command and General staff during the initial stages of the response. Pre-printing these checklists in a similar manner as was done for the wall-sized ICS forms may also be support initial staff response.The company used their local staff to fill positions required for the initial stages of the response; the company staff demonstrated the ability to order more resources and effectively expand the response quickly.The operational period estabilished was 24hrs beginning at 06:00 the following day. An incident briefing was held at 10:10 (approximately 45 minutes after the incident occurred) and vests were distributed to those given critical roles. The incident display board was put up on the wall and regularly updated and well used by all staff. After initial computer networking issues were resolved, mapping was also set up and used to display field information.The Planning Section Chief was effective in establishing a meeting schedule and holding briefings, planning and tactics meetings. The tactics and planning meetings were combined in the interests of time.Section 7.1 of CV1516-427, NEB Emergency Response Exercise Evaluation of Cochin's exercise in Regina, Saskatchewan on September 23, 2015 noted that NEB staff reminded Cochin staff to use ICS form 214 Activity Log during the response exercise. During this exercise, NEB staff observed Cochin staff directing that ICS 214s be used at each ICS position and subsequently observed ICS 214s being utilized by Cochin staff. This is an observed improvement.
Observation 4 - Communications
Date & time of visit: 2016-09-14 10:00
The Liaison role was established and, following some scoping guidance, was effective. Internal communications went smoothly and according to the guidance outlined in their ERP. The location of the ICP and incident made external communications difficult as cellular network coverage was poor. It was noted that relaying on Wifi for communications may not be appropriate and alternate plans need to be in place. External communications plans were made for company radios and shared with first responders (simulated). More radios were ordered by logistics, and the Cochin corporate IT department was requested to help establish a network and better connection for mapping and communications. Media statements were developed to address the public, landowners, media and affected persons. A communications plan was developed that would help coordinate first responders and other agencies responding, although for this exercise the first responders were unable to attend. A JIC was discussed regarding its set up, use and role during an incident such as this but not utilized for this exercise.Overall, communications in the ICS structure in the ICP went well. Staff observed some communication breakdown between Unified Command and the Section Chiefs but this was discussed and rectified during the exercise. It was also discussed that at the beginning of the exercise, potentially during the incident briefing to all staff, that reasons to interupt UC at any time be outlined and include: a life safety issue (someone is injured or killed); a threat or interruption is encountered (a crime, an accident scene, a wildfire...); etc... This would encourage staff to pass along critical information in a more timely manner. Although not presently included in the Cochin OSRP (ERP), consideration could be given to adding and using ICS forms 202A Command Guidance or 202B Critical Information Requirements in order to guide and facilitate timely information passage to UC.
Observation 5 - Tactical Response
The company had planned on doing a full boom deployment across the river at the bridge, but due to contractor issues and water levels, the actual deployment did not occur as planned. A small section of boom was eventually deployed, but not during the exercise.The company utilized its site-specific tactial plan from their ERP and quickly discovered this plan would not work given the river conditions (the water levels were too low). The Operations and Planning Sections worked together to develop a new tactical plan, based on the orginal template, that should work with the current river conditions. The plan involved the watershed authority shutting in the dam upstream to slow the in-river product migration to allow more time for booms to be deployed in deeper areas further downstream and water intakes boomed off and protected. The area on land around the pipeline leak was cordened off by staff and police. Hot/cold working zones were established and their delineation was informed via continuous air monitoring. Public access to the river was cut off via police and private security (on order) and the nearest populated center determined to be Outlook at approximately 20km downstream (northwest). The potential evacuation of the campground and golf course in Outlook was considered, but deemed unneccesary due to both being closed for winter. There were a few landowners that were notified after identification through the company EPZ maps in the ERP. Staging and working zones (hot/cold) were established (in theory only) and road blocks and site security discussed, plans developed and resources ordered via logistics. High level decontamination and waste management plans were discussed as well.Planning and operations identified key human health receptors (water wells and intakes) that would require protection and conducted hazard monitoring via air monitoring and water monitoriing (which would be conducted by the town of Outlook). Company staff should consider the need for increased emphasis on addressing environmental and socio-econmic concerns and establishing an environmental unit during future exercises.There appeared to be limited discussion surrounding the potential need to escalate or get big quickly, however the company did demonstrate the ability to expand the response by ordering more resources and discussing staffing needs and shifts.
Observation 6 - Post Exercise Debrief
Date & time of visit: 2016-09-14 02:00
A debriefing meeting was held post exercise to discuss the exercise and what participants and observers thought went well and also areas for improvement. Things that went well included:- communications between internal groups- ICS and exercise coaching- participation and engagement of agencies and staff- incident maps and display boards- ICS familiarity and knowledge levels of participants- ICS forms and tools used well- contractors and response organizations were on site to meet and participate- exercise progressed smoothly and timely- tactical plans from the ERP were sought and adapted rapidly and effectivelySome areas for improvement mentioned included:- increased local attendance from agencies- clearer communcations with response organizations and contractors regarding exercise instructions and expectations- more printers and resources needed for remote work and additional plans for communications when wifi is not available- river and water safety plans need to be made regarding upstream, downstream, and water level monitoring- more communication between section chiefs and unified command and within unified command- less reliance on control center to confirm a leak when visual confirmation has already been established; less hesitation to dispatch staff and response organization if any leak suspected with some sort of confirmation (in this case the visual confirmation should have been sufficient grounds to activate a response organization and respond quicker)After the debriefing, all ICS forms, feedback forms and notes were collected by the company to maintain exercise record and provide feedback into the company emergency management program.- know and remember the differences between objectives, strategies and tactics throughout the exercise- adjust the exercise scope and timeline for future exercises and include a field component when possible. Continue to push and expand capabilities with each exercise. The overall exercise objectives to practice initial response actions (including reporting procedures), practice using ICS, use the company Oil Spill Response Plan (OSRP), form a functional Unfied Command, and develop documentation of incident objectives and response activites, were all accomplished.The objectives to exercise each of the appropriate requirements of the NEB exercise evaluation form and prepare an IAP for unified command approval were not attainable during the exercise time frame and should be scoped to be more specific for future exercises.The objective to practice the company's preparedness for mitigating hazards and risks associated with emergency response was not fully achieved due in part to the company and contractor not being able to undertake field activities.
Observation 7 - Safety
Date & time of visit: 2016-09-14 14:00
Discipline: Safety Management
The exercise was conducted with due consideration for the safety of those participating. The hall had ample room for ease of movement and setting up tables and equipment. Tripping hazards, such as those posed by electric cords, were controlled via the placement of tables and securing to the floor with tape. The exercise was conducted in real time with current weather conditions reflected in the exercise. As such, with the temperature at 20c and a light wind, the product would readily evaporate reducing, but not eliminating, the hazards to responders. Personal protective equipment was in place based on the Safety Date Sheet for the pipeline product. However, it is imperative that responders remain upwind of any release and, if a release were to occur, this would need to be emphasized to first responders. Control zones for the release were delineated and mapped out. A Site Specific Health and Safety Plan, with primary and secondary hazards identified, was completed with the form populated as the exercise progressed.NEB staff were unable to assess site safety due to the cancallation of the boom deplpyment part of the exercise..
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
