Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Operating company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
A Functional EM Exercise conducted at the Taylor BC facility.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Overall observations including Exercise Planning and Conduct, Notification and Reporting, Safety, Response Management, Communications, Response Tactics and Post Exercise.
Date & time of visit: 2016-09-21 14:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
Exercise Planning and ConductAn exercise participant package was distributed prior to the exercise date identifying exercise objectives which were attainable, measurable and realistic for the exercise. In a separate meeting prior to the start of the exercise, the facilitator 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) - NEB staff did not attend the meeting. The exercise scenario was designed in consideration of the hazards and risks posed by the company's operations and the scenario adequately tested the company's ability to respond to an incident. Site security, public safety, and the need for medical assistance was appropriately planned to enable safe conduct of the exercise. A pre-exercise safety meeting was conducted on site, which identified potential hazards (Field Level Hazard Assessment) associated with the exercise, the controls employed to mitigate hazards and required PPE.Spectra Incident Commander provided a debrief of the sequence of events for the incident scenario. Topics of discussion included:1. the reason for the release (high flow prevention failed); 2. LEL readings to help inform operator safety and ability to reach isolation valve at rail car and rail dock isolation valve;3. identification that board operator would not be able to shut off pump to rail dock (in summer mode);4. discussed the need to remove all ignition sources;5. isolation6. ensure Spectra personnel have gas monitors and that they wait until the Emergency Response Team arrives at the incident site;7. names and roles of all Spectra personnel taken at muster site.
Notification and ReportingAlthough determination of the level of emergency was not exercised, NEB staff discussed this with Spectra and a Level 3 Classification was determined according to the company's Emergency Procedures Manual. Most notification actions were simulated as part of the scenario. External notifications such as those typically made to the NEB and Transportation Safety Board (TSB), were not exercised as part of the scenario.SafetySecurity and safety planning was a priority for Spectra at the incident site and at the ICP. Security staff were present and actively monitoring participants and entrances at the ICP which was located at the front office of the Taylor Gas Plant. All personnel were accounted for at the muster site.At the incident site, gas monitors were used by personnel. An ERT team member was walking ahead to test air quality and to ensure that it was safe to isolate the valve at the rail dock/rail cars. Fire protection system was verified and water was sprayed onto rail cars to lower the LELs.Response ManagementAn Incident Status Board was present in the ICP and was updated throughout the exercise. Ongoing status updates were also verbally communicated to exercise participants in ICP. A map of the Taylor Gas Plant was available and the incident site was marked. Efficient and effective discussion was observed, specifically between field/incident personnel and ICP. The following emergency response team roles were assigned: scribe, planning section chief, operations section chief, liaison officer and safety officer. Although an incident action plan was not prepared, it was discussed and objectives/priorities were developed for the incident. The Emergency Planning Zone was discussed and considered for the scenario.CommunicationsCommunications and communications equipment were effective and efficient although one comment during the debrief meeting indicated that the trunk system channels were not clear during the exercise and that maybe they should be discontinued. Liaison and communication between ICP and the incident site was excellent. The roles and responsibilities of the company versus emergency services personnel was understood and communication and coordination was clear.Response Tactics and Post ExerciseHazard monitoring was considered and conducted. Gas Monitors were available and in use at the incident site, with readings regularly taken and documented. The company conducted a response in accordance with its Emergency Procedures and supporting documents. Spectra had an incident command system in place and demonstrated knowledge and training in the command system. An Incident Command Post (ICP)was activated and was consistent in size with the company response. A tool truck, a pumper with ladder and an emergency response van were all present at the incident site.
Overall, the exercise was successful in achieving the exercise objectives. At the end of the exercise, each group provided their critique of how the exercise went. Generally, participants felt that communication between groups improved and they felt better prepared to participate in an actual response if required. For the ERT, the need for knowing what kind of emergency the team is trying to manage is essential in responding (i.e., if it was a medical emergency or a space confinement emergency etc.,). There was confusion on the alternate muster point as not all field personnel went to the same muster point. This was eventually communicated and corrected.Another learning from exercise participants was related to the quality of the water being used to spray the rail cars and the need for not pumping dirty water through water pumps. It took 30 minutes to flush water clean. Spectra inidcated that the company would address and make the appropriate changes to how frequently the fire water lines are flushed. The Fire Chief for the District Taylor indicated that it was not clear who was in charge at the incident site and that perhaps a "supervisor's vest" was needed. Spectra did indicate that the company supervisor at the incident site typically does have a vest but that it was unintentionally not used for this exercise. Spectra to ensure site supervisor or captain of ERT don a vest, in future. Lastly, the Fire Chief for the District of Taylor indicated that he should have had a radio in order to communicate witht the ERT captain. This was noted by Spectra and would be addressed through assignment of action items and resolution tracking and monitoring.NEB general observations were that participants at the exercise understood their roles. Liaising and cooperation between field personnel and the ICP was satisfactory and the overall flow of the exercise improved significantly as the exercise progressed. The incident management team addressed the exercise inputs efficiently through open dialogue and by following instruction and procedures as required. NEB staff noted that Spectra response personnel became more familiar and comfortable with their various roles in the ICS structure as the exercise progressed.
Compliance tool used: No compliance tool used
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
