Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Whitecap Resources Inc.
Operating company: Whitecap Resources Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Verify response capability during their full scale exercise in Boundary Lake.
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: 2018-10-17 11:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
Exercise Planning and ConductOn October 17, 2018 between 11:00 and 16:00 Whitecap conducted a full-scale emergency response exercise. The objectives of this exercise, as determined by the company, included:
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
Notification and ReportingThe Company was able to determine the level of emergency in accordance with its EPM. NEB staff noted that company personnel nervousness led to this determination taking longer than was expected but that staff were very safety conscious throughout this process and followed the appropriate steps as indicated in the ERP. Notifications were made to the appropriate company and regulatory personnel 1.25 hours from receiving the initial call. Requests for follow-up and continued reporting were observed with reasonable timelines established on each call. Once this level was determined staff continued to review and evaluate, adjusting the level accordingly as more information was available.
Observation 3 - Safety - Site Security and Public/Responder Safety
Site Security and Public/Responder Safety As indicated by the Company area residents were informed of the expected exercise and warning signs along with other exercise markers were in place to inform the public of activities in the area. The Company had a first aid attendant on site who assisted in the exercise as needed.No hazards that were not normal to operators were expected as equipment was not being shut down or manipulated so no additional safety plans were developed. Staff wore appropriate personal protective equipment, suited to the environment they were in (i.e.: field/ICP), this included hard hats, fire resistant coveralls, personal gas monitors, safety glasses, safety boots, and waited for self-contained breathing apparatus before approaching the well. A continuous gas monitor was used to monitor the surrounding area until the mobile unit arrived.
Observation 4 - Emergency Response Manual - Record Keeping
Record KeepingAn attendance sheet was established and captured participants, observers and evaluators. While ICS forms were not expressly used, participants and observers did take personal notes and when not required in the field, the first aid attendant served as a scribe. A basic incident status board was present in the EOC and other forms completed included:
Observation 5 - Response Management
Response Management While Whitecap personnel appear to be aware of ICS it was not readily apparent throughout the response and there was a clear reluctance to make use of some of the tools available to them (i.e.: vests, wall charts etc.). The tactical response was appropriately executed with a focus on safety but the overall exercise did not use ICS to establish a clear linkage between the objectives established within an operational period and the tactics and strategies needed to achieve the objectives. The Incident Commander was remotely located, while Whitecap utilized this method to more accurately reflect the realities of a true response this resulted in some role overlap and confusion. The mantra of ICS is to get big quickly and NEB Staff are of the view that personnel manning the ICP need to be fully aware of what role they are playing and have documented lines of communication with the incident commander. Tasks were assigned, that when prompted, Whitecap staff were able to self-identify what role those tasks would align with as outlined in the ERP. In order to avoid confusion and ensure that all tasks are completed NEB staff are of the opinion that roles appropriate to the scenario should be assigned rather than tasks from within each role. Roles should be assigned early on by the Company's IC with clear identification of priority actions for each Officer and Chief in the Command and General Staff. Section Chiefs and other roles need to be identified in the ICS 207 organization chart and provided to exercise participants prior to the exercise. It is important to practice the Planning ‘P’. NEB Staff are of the view that, at a minimum, that in future exercises it would be beneficial to formalize or identify in some manner the meetings that are occurring. The linkage between the intended work and the objectives established by UC needs to be clear. Whitecap personnel indicated that many meetings took place but were done informally and conducted via cell phone with notes being taken on both sides. NEB staff were able to observe some of these calls but it was not clearly observable what each call pertained to other than basic updates regarding the response. The Crisis Management team from Whitecaps Head office was utilized throughout the exercise however, given that the Incident Commander was located off site there appeared to be two silo’s created with the IC working in one, conducting the notifications and liaising with head office and the Deputy Incident Commander working in another managing the actual response. A clear demarcation of each role and communicating this out would help ease confusion during the response.It is the NEBs recommendation that evaluations also be shared with Company personnel. It was observed throughout the exercise that Whitecap personnel were largely unaware of previous evaluations. Overall staff conducted themselves in a safe and effective manner but failed to recognize the importance of being able to demonstrate their understanding of the Incident Command System. Had Whitecap personnel been briefed on previous evaluations they may have been able to better visibly demonstrate and/or communicate throughout the exercise how they were meeting the objectives. Following the end of the exercise, NEB staff were able to ascertain that staff had a much greater understanding of the Incident Command System then they demonstrated throughout.
Observation 6 - Communications
Communications While not initially indicated there were three methods of communication available for use between the ICP, field responders and participants. This included phone, radio and text. NEB staff observed all three being effectively used as well as participants taking the initiative to explore other options of finding out the information they needed, whether that was driving to the site or asking the Deputy Incident Commander.
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
