Compliance Verification Activity Report: CV1819-141 - ISH Energy Ltd.

Overview

Compliance verification activity type: Emergency Response Exercise

Team:

• Inspector 1618
• Inspector In Training 2414T

Regulated company: ISH Energy Ltd.

Operating company: ISH Energy Ltd.

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Emergency Management

Rationale and scope:

As part of the NEB’s compliance planning risk model, ISH Energy Limited has been identified for an emergency exercise evaluation to verify response capabilities. The full scale exercise will be conducted at a site that is truck accessible. The exercise will be limited to initial response to a pipeline release. Recovery activities are out of scope.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Desan Pipeline

Facility Types

• Pipeline
• Meter station
• Other
• Pipeline

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Emergency Response Plan (ERP)
• ISH Energy Ltd., Desan Pipeline Emergency Response Procedure (ERP)
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems
• CSA Z246.1 - Security Management for Petroleum and Natural Gas Industry Systems

Observations (no outstanding follow-up required)

Observation 1 - Exercise Planning and Conduct

Date & time of visit: 2018-07-18 09:15

Discipline: Emergency Management

Categories:

• Exercise Planning and Conduct
• Scenario Briefing
• Site-specific Hazards
• General Safety Briefing
• Scope of Exercise
• Participant Package
• Exercise Objectives

Facility:

Observations:

An exercise package was shared with the evaluators prior to the exercise and provided to the participants on the day of the event.

 The objectives for the exercise were described in the exercise package as follows under the heading "Purpose”.

• To reinforce worker Emergency Response training with an emphasis on problem solving, rapid decision making and understanding of concepts
• Evaluate ISH resources and tactics
• Evaluate each section of the incident response
  • implementation of ICS
  • Defining levels of emergency
  • Sharing responsibilities
  • Use of all of the ICS forms
  • Corporate Command Operations Group meeting and briefing to VP
• Provide opportunity for improvement.
• The exercise coordinator briefed the participants on the rules of play, the scope, roles and the scenario. He also outlined site safety including a muster point.
• The Desan pipeline is remote. The terrain in the area is muskeg, water and stunted trees. A simulated incident locale was chosen that is helicopter access only. The site for the actual boom deployment was accessible by truck. Trucks were used to simulate helicopter access.
• There was negligible risk to public safety due to the remote location.
• A Safety Officer was appointed to attend to the incident site. A tail gate safety meeting was held at the incident site and the onsite Safety Officer (SO) addressed appropriately addressed worker safety.
• The exercise facilitator appropriately addressed overall responder safety including bear safety. Company responders were equipped with personal 4-gas monitors. Standard PPE was required outside of the company office (ICP) ‘and at the incident site.
• The Incident Commander, SO, Ops Chief (Deputy IC) kept personal logs. A scribe maintained displays including a site map. The displays also included an organization chart, action items, resource requests, time of events. The scribe also took photos of the displays.

Compliance tool used: No compliance tool used

Observation 2 - Notification and Reporting

Date & time of visit: 2018-07-18 09:00

Discipline: Emergency Management

Categories:

• Notification and Reporting
• Notification & Reporting as per EPM
• Incident Classification

Facility:

• Desan Pipeline (Pipeline)

Observations:

• The responders relied on the assessment of the Deputy IC at the incident scene for determination of the incident level.
• The staff at the EOC completed the notification to the TSB and NEB OERS.  The participants did not simulate notification to provincial energy regulators (BC Oil and Gas Commission, or Alberta Energy Regulator) or BC Ministry of Environment and Climate Change.   

Compliance tool used: No compliance tool used

Observation 3 - Safety

Date & time of visit: 2018-07-18 09:00

Discipline: Emergency Management

Categories:

• Safety
• Safety Plan
• Personal Protective Equipment
• Monitoring/Safety Equipment

Facility:

• Desan Pipeline (Pipeline)

Observations:

• The Safety Officer was reported to be developing a safety plan and log (plan not observed). He deployed to the incident site. 
• Personnel wore appropriate PPE. 
• Signage was deployed at the ICP. Resources for mobile air monitoring and decontamination were requested by the ICP staff.

Compliance tool used: No compliance tool used

Observation 4 - Response Management

Date & time of visit: 2018-07-18 09:00

Discipline: Emergency Management

Categories:

• Response Management
• Roles and Responsibilities
• Emergency Procedures Manual
• Command and Coordination Centers
• Span of Control
• Chain of Command
• Response Priorities/Incident Objectives
• Response Structure
• Mobilization of Resources/Equipment
• Operational Period
• Meetings & Briefings
• Incident Status Board
• Maps and Modeling

Facility:

• Desan Pipeline (Pipeline)

Observations:

• The IC referred to the position checklist in the Emergency Procedures Manual (EPM).  The Field Supervisor (Deputy IC, Ops Chief) referred to the Incident Classification Matrices in the EPM. Other roles used ‘Quick Lists’ from the EPM for ordering resources . Personnel in the EOC at Head Office also referred to the EPM in contacting the NEB OERS.
• The company responders showed familiarity with ICS forms and procedures.
• The Desan Battery site (which is also the control room) functioned as the ICP.
• Appropriate roles in the Incident Management Team were defined and appropriate span of control was maintained.
• Efforts were directed appropriately at isolating the line, and minimizing environmental impacts. One area of discussion was the need for participants to make a clearer distinction between objectives, strategy and tactics.
• A small field office such as this one expands by ordering resources from supply centers in Fort Nelson, Fort St John and elsewhere that are flown in to the incident site. The company has a spill kit that can be airlifted from the Desan Battery site  to an incident site.   
•  The company did have a ready list of suppliers including labourers. The exercise did identify some additional resources, fencing, tenting, wind socks, mobile vapour monitoring, decontamination, wildlife hazing that it might choose to store at the battery site for rapid airlift.
• An operational period was not really clarified though all participants were aware that the scenario could not be resolved in a single day. The IC and the Plans Chief (PSC) at Head Office appropriately evaluated the risks, benefits and logistics of keeping personnel at the incident site overnight in genuinely inclement weather at a remote location. Equipment that would be needed to develop a fully functioning site would not have arrived until the next day. 
• The IC  briefed the participants on the situation as he handed out checklists for differing roles in the response. In addition to the PSC, Head Office also provided the PIO, LO, and the FSC. Formal meetings were not held. The IC, incident site (Dep IC) and Head Office kept in contact by using a poly-com for an open teleconference. The Head Office in Calgary provided very helpful support to the IMT.  
• ICS vests were not used, but given the small number of IMT participants, not required. 
• A large scale map of the pipeline was used in the initial stages of the response in order to pinpoint the incident site prior to confirming by a flyover (simulated).
• The scribe posted significant events for tracking purposes.
• The field observer role was filled by the Deputy IC at the incident site and at the downstream valve site.
• Participants signed in at the start of the exercise. 

Compliance tool used: No compliance tool used

Observation 5 - Communications

Date & time of visit: 2018-07-18 09:00

Discipline: Emergency Management

Categories:

• Communications
• External Comms Strategy
• Internal Comms Strategy
• Communications Equipment
• Organization of Stakeholders
• Coordination with Responders
• Response Tactics
• Site Layout
• Plans and Procedures
• Site Security/Access Management
• Control Points
• Hazard Monitoring
• Deployment of Containment Equipment
• Protection of Environmental Receptors
• Protection of People

Facility:

• Desan Pipeline (Pipeline)

Observations:

• Considering the small scale of the response, the IMT did not use forms for work assignments, or resource requests (ordering or expense tracking). This should be considered for future exercises.
• The LO at Head Office completed the NEB OERS notification.  Other agencies regulators, and spill cooperatives were not contacted.
• Head Office in Calgary provided effective communications support. The VP/COO is responsible for media messaging and a holding statement was available.

Compliance tool used: No compliance tool used

Observation 6 - Response Tactics

Date & time of visit: 2018-07-18 09:00

Discipline: Emergency Management

Categories:

• Response Tactics
• Site Layout
• Plans and Procedures
• Site Security/Access Management
• Control Points
• Hazard Monitoring
• Deployment of Containment Equipment
• Protection of Environmental Receptors
• Protection of People

Facility:

• Desan Pipeline (Pipeline)

Observations:

Tactical Response

•  Spill volume was estimated at 6-8 cubic meters. The oil was described as moving slowly along the right of way in a spill of 125 X 50 feet and 75 feet from a creek to the north of the right of way. The Dep IC classed the incident as a Level II Emergency. Socio- economic impact potential was limited in the scenario.
• The company responded according to its emergency procedures. 
• The responders focused on containing movement of the released product and isolating the section of pipe by closing valves. 
• This is a remote site without local landowners. 
• The responders simulated contacting trappers through the Dene Tha’ Office. 
• The responders learned that they would need more equipment to set up an effective site. The responders referred to a ‘hot zone’ but did not appear to be considering setting up hot, warm and cold zone demarcations at the site for protection of workers. They had not provided for decontamination but did order equipment.  Much of that material would have to be ordered and flown to the site in subsequent operational periods.
• The potential for oiled wildlife, particularly bears, was considered by the IMT.
• The ERP provided information about the control point access, landing site, water flow, and the direction of pipeline flow. 
•  Decontamination resources  were in process. 
• The responders did consider how to remove collected oil, whether in bladders or barrels. The issues involved the pros and cons of air lift versus waiting to freeze up and hauling out by quad or on skids (barrels).  Technically, this issue was out of scope but appropriately considered by the IMT.
• The water course at the control point is a.remote; shallow, sluggish stream and muskeg without water intakes. 
• Mobile vapour monitoring was ordered. Responders had personal 4 gas monitors. 
• Primary and secondary booms were deployed.
• Field staff displayed familiarity with boom deployment and appropriately set up the boom configuration.

Compliance tool used: No compliance tool used

Observation 7 - Post Exercise

Date & time of visit: 2018-07-18 09:00

Discipline: Emergency Management

Categories:

• Post Exercise
• Debrief Meeting
• Collection/Filing/Completion of Documents
• Evaluation Against Objectives

Facility:

• Desan Pipeline (Pipeline)

Observations:

The debrief was held when all of the field participants returned to the ICP and had been given a chance to complete their logs. The participants at Head Office also contributed. 

Comments noted included: 

• Response planning during the initial phase of the incident is challenging.
• A minimum of 3 people is needed in the ICP.
• Telecommunications with Head Office and the field is very helpful.
• Showing control points on the sales line map complete with latitude and longitude of the control points would be useful.
• The Transportation Safety Board notification worked well but inserting the information into the OERS presented some challenges to company staff. NEB Staff note that since the exercise, ongoing improvements to the OERS have addressed issues such as those noted by ISH.
• Company will need to explore overnight shelter for personnel in the field.
• The Exercise Coordinator suggested that any lessons learned could be incorporated in procedures and shared with the participants  

The Exercise Coordinator reviewed the goals of the exercise per the exercise guide and participants concluded that the goals had been met.

Recommendations from NEB Staff. Future exercises should consider:

• Increased use of ICS forms including ICS 201.
• More practice with identifying and differentiating objectives, strategy and tactics.
• Increased focus on formal development and sharing of an event and site safety plan
• Formal development of other response plans such as Wildlife Management Plan and Communications.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: