Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: TEML Westspur Pipelines Limited
Operating company: TEML Westpur Pipelines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Verify response capability during a functional exercise on October 24 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: 2018-10-24 09:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
The pre-exercise meeting commenced at 09:00 at the TEML Office in Estevan, Saskatchewan. A site safety briefing was given and a participant package and brochures were distributed. The exercise purpose, scope, objectives and ground rules were reviewed with the group.The exercise objectives included:- Implementation of Incident Command System (ICS) by way of Incident Management Team (IMT) and Field Response Team.- Ensure ongoing safety of personnel and the public- Test the Emergency Procedures Manual (EPM) and other applicable plans and procedures- Develop applicable environmental plans- Test internal and external notification procedures (through Simulation cell (SIMCELL)- Complete initial Incident Action Plan and ICS 201 packet- Test tactical response including control point selection, boom deployment and staging area layout/controls.The scenario design was based on leak from an oil line into a water body. At 08:45 Estevan Control Centre notified Midale Terminal and Estevan Office of a ATMOS alarm on the line. The Control Centre remotely shut down the pipeline. A TEML operator was dispatched to investigate via the nearest road crossing and discovered product in the Reservoir. The operator began notifications and the IMT were assembled in the Estevan EOC.The participant package included a complete outline of the scenario involved. Separate rooms in the office were used to simulate the EOC, the incident site, and a simulation cell (SIMCELL). The SIMCELL played external agencies and individuals who would be notified during an incident and provided information from the EOC staff throughout the exercise. Each room had separate sign in/sign out lists to maintain accountability. The exercise involved TEML staff as participants, support, evaluator and observers and allowed NEB to participate as evaluators. NEB staff are of the view that the exercise design considered potential hazards and situations realistic to TEML's operations. There was adequate time for all of the exercise goals to be achieved. The participants were able to fully engage in the ICS process, roles and EOC functions.
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
The notification process occurred as follows:Estevan Control Centre received an ATMOS alarm on one of the pipelines and notified Midale Terminal and Estevan Office. The Control Centre remotely shut down the line while a TEML operator was dispatched to the area the alarm was coming from. Upon observing product in the water, the operator began notifications as per the EPM and the Incident Management Team was notified and assembled to the Estevan EOC.A Liaison Officer was appointed and began all notifications and reporting as per the company EPM.The incident was discussed early on as more information was gathered and classified as a level 3 due to its potential to worsen.
Observation 3 - Safety
Safety began with a detailed job safety analysis (JSA) created by the field operator and signed onto by all responding personnel upon arrival at the field "site". The field crew considered hazards at the site relating to slips, trips, falls, hazardous atmospheres/ toxic gasses, water safety, boat safety, and hot, warm, cold zones to be established. Appropriate PPE was discussed and included personal gas monitors, PFDs, and all standard FR gear as well as Tyvek suits and gloves to use for oil clean up. Decontamination was also discussed, planned, and ordered via the EOC.The EOC was set up with safety considered, such as power cords secured to the floor. A sign in/sign out system was used for all personnel in the EOC and Field Site rooms. This is an effective means of tracking personnel at both locations.The roles of Safety officer and site safety officer were filled with experienced staff members. The Safety Officer in the EOC began creating a comprehensive incident safety plan.
Observation 4 - Response Management
The Incident Command System (ICS) was used for the response to the incident. The company operator dispatched to the incident site confirmed the incident and began notifications as per the ERP.The ERP was activated and company staff began establishing an Emergency Operation Centre (EOC) at the Estevan TEML Office.At the EOC, a company Incident Commander was appointed and assigned roles in the incident management team considering their company position and training. They fulfilled their role-specific responsibilities and utilize the company ERP and training tools well. All external calls were made to the simulation cell (located in another room) for authenticity of notifications. Calls were also made between the field site IC and the Operations Section in the EOC. This insured single point contact and maintained the chain of command. The EOC was established quickly and staffed for training purposes. The span of control was maintained throughout the incident at both site level and EOC level, and chain of command was displayed at the incident site on the 207 form as well as at the EOC on the incident status board. The response structure followed the company ERP guidelines and staff were familiar with the structure. Staff were very well trained in ICS system and roles.Both field site and EOC personnel thoroughly understood and adhered to the chain of command and process to request and order all resources as needed. Resources such as response trailers with equipment, boats, boom, anchors, pfds, trailers, light stands, rig mats, food/water, facilities, hotel rooms, etc were all ordered through the logistic section and using the simulation cell.Incident response priorities and objectives were discussed and appropriately developed right away. These priorities and objectives were further refined as more information was gathered and displayed as the response progressed. Considerations for staff and public safety, containment and environmental protection were discussed and planned for. The potential for the incident to escalate was also discussed from both a safety and emergency response perspective.Operational period was established and staff insured to put in resource requests for their position to be filled (if required) for night shifts.Meetings were well organized and concise; the Planning Section Chief facilitated the meetings, insured attendees were limited to only those required and kept the meeting discussions on task. Goals of each meeting were achieved in a timely manner.The situation unit leader began building an incident status display immediately and maintained up to date information on it throughout the exercise.Maps were displayed in the EOC to show the site location and layout. Trajectory modeling was undertaken in the EOC to help determine containment tactics.
Observation 5 - Communications
The Public Information and Liaison Officers functions were assigned immediately and were well-coordinated. The knowledge gatherers, Liaison Officers (LO) and Public Information Officer (PIO) frequently shared information and updates with other EOC members and agencies to help inform message development and media responses.An external communication strategy was formulated with messages prepared for affected persons, the public and media. PIO demonstrated that the company can respond appropriately and communicate with the public and other potentially affected parties for the scenario tested. They addressed the public's need for information through the establishment of a public information line and media messaging on local radio.The PIO and LO were actively involved in the incident command briefings and meetings where they spoke to their completed and upcoming tasks. Exercise inputs and key information were discussed and disseminated amoung EOC staff and relayed to the public through media messaging. Meetings and information sharing was frequent, all participants understood their respective roles and how to action requests.
Observation 6 - Response Tactics
The exercise was a functional table top so there was no actual incident site established or visited. A room in the Estevan office served as a location for the field response team to gather and do what they would be undertaking in the field via discussion, forms and diagrams.The "site of the incident" was located on the northern shoreline of a large reservoir northeast of Estevan, with the pipeline having leaked underneath the water body. There were light winds and it was approximately 10 degrees and overcast.A company operator was dispatched to site to confirm if there was an incident. He confirmed that there was an incident and began notifications to company superiors as per the ERP.The operator then began to establish hazard zones and a staging area on the north bank of the reservoir on relatively flat, solid ground in an open area. Road blocks were established along the road nearest the site (the 606) and single lane traffic was allowed through. RCMP were contacted (Simulation cell) to aid with this task. Boat traffic was also detoured from the area by TEML staff. Upon receiving an alarm, the Control Centre shut in the closest valves for the pipeline upstream and downstream to isolate the section. Company staff were dispatched to the field to verify the valves were closed. Closing the valves limited the amount of product available to continue leaking. After initial notifications were made, the company established an EOC in Estevan. The TEML safety officer at the site considered the hazards posed by the product released into the water and established PPE requirements including air monitors and site safety rules. TEML staff began arriving to site and requesting PPE, staging materials, clean up materials, additional personnel and mutual aid from coop groups nearby to provide spill response equipment. They also requested environmental groups to attend to wildlife, water intakes, and sampling, and a security company to provide site security.There were no persons requiring evacuation, but boat and road traffic to the area was impacted and limited by TEML and private security contractors to maintain scene safety and limit exposure.Water intakes in the reservoir were proactively protected by environmental contractors hired by TEML, Fish and Geese were identified as a potential environmental receptor and assessed for impacts. 10 Geese were oiled and attended to by the a wildlife contractor group hired by TEML.
Observation 7 - Post Exercise
Date & time of visit: 2018-10-24 15:00
After the exercise was finished, a debriefing meeting to discuss the learnings from the exercise was held. Positive learnings from the exercise and areas for improvements were discussed and noted. All documentation generated was collected and will be filed and reviewed by TEML emergency management staff.NEB staff are of the view that all exercise objectives were met. NEB Staff do not have any substantive comments regarding areas for improvement. NEB Staff are of the view that, based on this exercise, TEML demonstrated that it is prepared to respond appropriately to an oil spill and that it has properly trained employees and contractors and access to sufficient and appropriate resources to enact a response.
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
