Emergency Response Exercise Evaluation – Plains Midstream Canada ULC - 1516-500

1.0 EXERCISE EVALUATION OVERVIEW

The Emergency Response Exercise Evaluation is one of many tools the NEB uses to evaluate the various elements of a regulated company's emergency management program for meeting the requirements of the NEB Onshore Pipeline Regulations and Canadian Standards Association CSA-Z662-15 (Z662-15).

The NEB recognizes that emergency response exercises are only one part of a company's overall emergency management program and that exercises provide an effective learning experience for participants that complement the company's broader training and continuing education programs. The NEB expects that upon completing an exercise, a company will compile the lessons learned and participant feedback, and will act on this information to continually improve its emergency manaprogram. It is in this context that there is no "pass" or "fail" associated with the NEB exercise evaluation, and the evaluation does not assess the competency of individuals. Rather, should any non-compliance with the requirements be observed, the NEB will require corrective actions be taken by the company in order to address the non-compliance. In most cases the non-compliance will require a Notice of Non-Compliance be issued by the NEB that details the corrective action(s) to be taken by the company and deadline date(s) for completion.

There are five (5) potential responses to each question in the evaluations, these are: Yes, No, Not Applicable, Not Observed and Needs Improvement. Yes means that the element was observed and no non-compliances with regulatory requirements were identified, No means that the element did not meet regulatory requirements, is therefore in non-compliance, and will require corrective action be taken by the company. The comment section should clearly describe the nature of the non-compliance. Not Applicable (N/A) means the element is not applicable to the exercise and is not assessed. Not Observed means that NEB staff did not observe the element, although it may have been tested during the exercise. Not Observed does not mean that the element was in non-compliance; simply if it was not observed then it cannot be assessed. Needs Improvement means that the element was assessed and meets requirements; however there is room for improvement. NEB staff may make recommendations to the company on potential improvements, but these are not requirements, no corrective action is necessary, and the NEB will not follow-up on the recommendations to the company. The Comments section is provided in order that NEB staff can provide a narrative assessment. This section may highlight aspects of the exercise that were well executed, describe areas for improvement or provide further explanation to why an element is in noncompliance.

2.0 EXERCISE DETAILS

2.0 EXERCISE DETAILS
Regulated Company Plains Midstream Canada ULC
Operator Plains Midstream Canada ULC
Activity Number 1516-500
Condition from an Order No
Order Number  
Date of Exercise 9 March 2016
Exercise Name Prairie Pipeline Functional Exercise
Location Kerrobert, Saskatchewan
Company Exercise Type Functional
Company Representatives There were approximately 30 Plains Midstream employees and contractors that participated in the Prairie Pipeline exercise.
NEB Staff Personnel from the NEB included Emergency Management Specialists
Other Participants National Energy Board, Bissett Consulting, EmergWest

SECTION A - EXERCISE PLANNING AND CONDUCT

3.0 Exercise Planning

3.1 Was an exercise participant package distributed prior to the exercise date?

Yes

3.2 Were exercise objectives attainable, measurable and realistic for the exercise?
(CSA Z662-15 Clause 10.5.2.4)

Yes

3.3 Did the facilitator go 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)?

Yes

3.4 Was the company exercise scenario designed in consideration of the hazards and risks posed by the company's operations and was the scenario appropriate to adequately test the company's ability to respond?

Yes

3.5 Were site security, public safety, and the need for medical assistance appropriately planned to enable safe conduct of the exercise?

Yes

3.6 Did the facilitator conduct a safety briefing, including identification of the potential hazards participants may be exposed to during the exercise, the controls to mitigate the hazards, required safety equipment and PPE (OHSR Section 19.6)?

Yes

3.7 At site, was a safety meeting(s) conducted as required to review site specific hazards and controls for participant safety?
(e.g., SWP, JSA, etc.)? (CSA Z662-11 Clause 3.1.2 (f))

Yes

3.8 Was there effective record keeping throughout the exercise such as a list of participants and observers, forms, event logs and participant feedback?
(CSA Z662-15 Clause 10.4.3.2 and 10.5.2.4)

Yes

Section 3 Comments:

The exercise was well planned out. The company, Plains Midstream Canada (PMC), provided a participants package and held a meeting with us a week before the exercise to discuss the details. This particular exercise scenario was very realistic for the area in the southern Saskatchewan. The objectives were to practice using ICS, utilizing the "Planning P" up to the tactics meeting, use the company Emergency Response Plan (ERP) and Field Operators Guide (FOG) tools, establish communications between ICP and EOC, and identify lessons learned from the exercise. All of these objectives were realistic, measurable and achieved. The facilitators discussed the exercise rules, site safety and security measures. All new staff and visitors to the site were required to take the site safety orientation prior to the exercise. The record keeping was ongoing throughout the exercise and safety meetings were conducted for each specific site used at the facility.

SECTION B - EXERCISE IN PLAY

4.0 Notification and Reporting

4.1 Did the company determine the level of emergency or severity of the incident according to its EPM?

Yes

4.2 Were the notification and reporting procedures followed according to the EPM and done in a timely manner?
(OPR s. 32. OPR ss. 52(1) and CSA Z662-15 Clause.10.5.2.4)

Yes

Section 4 Comments:

The level of emergency was determined by the IC using the company Hazard and Risk matrix as found within the Emergency Response Plan (ERP). The incident was established to be a level 3 incident by the Incident Commander (IC). Notifications and reporting procedures were followed according to the ERP and were carried out quickly. The National Energy Board (NEB) was notified within the hour of the initial incident briefing.

5.0 Safety

5.1 Was a safety plan developed for the exercise scenario and was a safety briefing conducted with responders and other field staff, including hazard identification, hazard controls, personal protective equipment, muster area, control zones, site safety, public safety and a decontamination area?
(OHSR Section 19.6)

Yes

5.2 Was the required personal protective equipment available and used properly by responders and other field staff (e.g.: safety harnesses, breathing apparatus, chemical protection, personal monitors, etc.)?
(CSA Z662-15 Clause 10.2.9.2 and COH&S Regulations, Part XII, sections 12.1-12.16)

Yes

5.3 Was the required safety equipment available, and properly used by responders and other field staff? (e.g.: fire extinguishers, signs, barricades, rescue, LEL meters, air monitoring, decontamination, etc.)?
(OPR paragraph 36(b) and/or 46(2) (d) and CSA Z662-15 Clause 10.5.2.4)

Yes

Section 5 Comments:

The Safety Plan for the exercise response was effectively conducted prior to the response. All responders (only PMC personnel were involved in the response of this exercise) were required to wear coveralls, hard hats, eye protection, gloves, steel toed boots, and personal vapor monitors according to the Safety Plan and ERP.

Located within the company's Kerrobert facility yard, the field staff set up proper road blocks using barricades and had air monitoring kits out for training.

6.0 Response Management

6.1 Did the company respond in accordance with its Emergency Procedures Manual and supporting documentation?
(OPR s. 32 & CSA Z662-11 Clause 10.5.2.4)

Yes

6.2 Did the company have an incident command system in place and demonstrate knowledge and training in the command system
(ICS or another applicable incident management system)? (OPR s. 32 and CSA Z662-11 Clause 10.5.2.4)

Yes

6.3 Was a Command Post activated, consistent with the company response procedures?
(OPR s. 32 & CSA Z662-11 Clause 10.5.2.4)

Yes

6.4 Were roles assigned consistent with the company's EPM?
(OPR s. 32 & GSA Z662-11 Clause 10.5.2.4)

Yes

6.5 Was span of control appropriate (e.g., 5-7 reports)?
(CSA Z662-11 Clause 10.5.2.4)

Yes

6.6 Was the chain of command maintained and consistent with the company's response structure?
(CSA Z662-11 Clause 10.5.2.4)

Yes

6.7 Were incident objectives and response priorities established and appropriate?
(CSA Z662-15 Clause 10.5.2.4

Yes

6.8 Did the company expand the response structure as required to meet the requirements of the scenario?
(e.g., operations, planning, logistics and finance/admin or equivalent functions put in place as required) (CSA Z662-11 Clause 10.5.2.4)

Yes

6.9 Did the company demonstrate the ability to mobilize the required personnel and equipment in a timely fashion?
(e.g.: "get big quick?") (CSA Z662-15 Clause 10.5.2.4)

Yes

6.10 Was an Operational Period established?
(This may not apply to a short term event such as a gas release) (CSA Z662-15 Clause 10.5.2.4)

Yes

6.11 Was an incident briefing held?
(CSA Z662-15 Clause 10.5.2.4)

Yes

6.12 Were the tactics and planning (or equivalent) meetings conducted and effective?

Yes

6.13 Was there visible role ID (e.g.: vests or labels) for the critical roles?
(CSA Z662-15 Clause 10.5.2.4)

Yes

6.14 Were appropriate maps available, used and up-to-date?
(e.g.: environmental, residents, urban areas, transportation routes, cables, pipelines, powerlines, electric, water, sewer, etc.) (CSA Z662-15 Clause 10.5.1.1(b) and 10.5.2.4)

Yes

6.15 Was the incident status displayed and maintained?
(CSA Z662-15 Clause 10.5.2.4)

Yes

6.16 Were dedicated Field Observers used?
(CSA Z662-11 Clause 10.5.2.4)

Yes

6.17 Were check-in procedures implemented?
(OPR s. 47, CSA Z662-15 Clause 3.1.2(1), 10.5.2.1(b) and/or 10.5.2.4)

Yes

Section 6 Comments:

Plains Midstream Canada (PMC) used their ERP and demonstrated their knowledge and training in Incident Command System (ICS). They activated their Incident Command Post (ICP) and Calgary Emergency Operations Center (EOC) according to their ERP and assigned roles while maintaining the proper span of control throughout the exercise. The participants followed the chain of command and critical roles were identified by wearing vests and tables identified with colored cones. The Unified Command included the NEB Incident Commander and identified the NEB as the lead agency. A Unified Command meeting was conducted and immediately following the UC meeting. An initial incident briefing was held by the appointed Incident Commander and signaled the activation of ICS for a Level III (3) incident. An operational period of 24 hours was established and the incident status was displayed and maintained. There was one dedicated field observer outside at the road block site. Check-in and check-out procedures were implemented for the ICP and road block sites. The logistics branch was instructed to call those response organizations and contractors in the ERP to verify their response capabilities and times; this was an excellent addition to the exercise as a few contractors were identified as no longer in business or able to offer services in the event of a real incident. A live mapping tool was used to display any information that came into the ICP and was also viewed in the EOC to create a common operating picture. The mapping tool incorporated updated environmental sensitivity mapping. The response to the scenario was appropriate in size and functions and it was clear more resources could be called upon if needed. The incident objectives and response priorities were established quickly and Unified Command moved on to working with the Planning and Operations sections to prepare for strategies and tactics. Planning and Operations prepared the strategies and tactics which were presented in the Tactics meeting. At the conclusion of the tactics meeting the exercise was stood down. A debrief meeting followed.

7.0 Communications

7.1 Were communications and communications equipment effective and efficient?
(e.g., orders, resource requests, work assignments, reporting) (CSA Z662-15 Clause 10.5.2.4)

Yes

7.2 Was the liaison role established and did it communicate/coordinate with agencies?

Yes

7.3 Was an external communication strategy formulated?
(e.g.: preparation of messaging for landowners, affected persons, the public and media, coordination of communications with agencies and other responders, communications methods and timing, authorizations for release of information, and interactions with media) (OPR s. 32 & CSA Z662-15 Clause 10.5.2.4)

Yes

7.4 Were the roles and responsibilities of the company versus emergency services personnel understood and were there communication and coordination between these parties?
(OPR s. 32 & CSA Z662-15 Clause 10.5.2.4)

Yes

Section 7 Comments:

Communications with outside agencies and response partners was simulated by use of a simulation centre controlled by Bissett through the appointed Liaison officer. The Calgary EOC prepared a media briefing with input from Unified Command.

8.0 Tactical Response

8.1 Did the company conduct a tactical response according to its Emergency Procedures and supporting documents?

Yes

8.2 Were alternate strategies and tactics considered? (CSA Z662-15 Clause 10.5.2.4)

Yes

8.3 Were impacts on local residents considered and was the nearest populated centre and its distance from the emergency site determined?

Yes

8.4 Were landowners and potentially affected persons notified?
(CSA Z662-11 Clause 10.5.2.4)

Yes

8.5 Was an effective emergency site layout established and identified?
(e.g.: hot/cold zones, staging, decontamination, fagging, barricades, signs, etc.) (CSA Z662-15 Clause 10.5.2.4, Cl. 10.5.2.1(b) and OPR s. 47

Yes

8.6 Was site security maintained?
(CSA Z662-15 Clause 3.1.2 (f) or if it is related to people, Clause 10.5.2.4 and/or OPR s. 47)

Yes

8.7 Were road block locations simulated or established?
(CSA Z662-15 Clause 3.1.2 (f) or i f it is related to people, Clause 10.5.2.4 and/or OPR s. 47)

Yes

8.8 Were control point(s) pre-identified based on hazard identification and risk assessment, and were they established according to the ERP or tactical plans?
(OPR s. 32, s. 48 & CSA Z662-15 Clause 10.5.2.4)

Yes

8.9 Was decontamination considered or in place?
(OPR s. 47,CSA Z662-15 Clause 10.5.2.1(b) and/or 10.5.2.4)

Yes

8.10 Did the company consider waste management?
(OPR s. 32,s. 48 & CSAZ662-15 Clause 10.5.2.4)

Yes

8.11 Did the company identify key human health receptors (e.g.: eater intakes/wells) for protection?

Yes

8.12 Was hazard monitoring considered or conducted?
(e.g.: vapor monitoring, downstream monitoring) (OPR s. 47)

Yes

8.13 Did the company successfully deploy containment equipment?

Yes

Section 8 Comments:

Communications strategies were established for messaging to area residents and in the event of evacuation.

Road blocks were set up on company property as well as personal air monitors and one air monitor with a pump for hazard monitoring. Logistics ordered additional air monitoring equipment from Calgary. Hot/cold zones were established (simulated) as well as site security and the tactical response to deploy containment equipment was discussed and planned using the environmental sensitivity maps and live mapping tool. Decontamination and waste management were considered for this exercise but not set up. There were two landowners in the affected area that were considered for evacuation and one industrial use water well identified to be protected. Deployment of equipment was not in the scope of the exercise. However, concurrent with the exercise, Plains staff set-up booms, tanks and skimmers for equipment practice in the Kerrobert yard.

9.0 Environment & Socio-Economic Considerations

9.1 Did the company organize the environmental stakeholders?

Yes

9.2 Did the company identify environmentally sensitive areas for protection?
Was appropriate mitigation established for environmental and socio-economic resources potentially impacted by conducting the exercise (e.g.: approval(s) from agencies, protection of sensitive areas)?

Yes

9.3 Did the company have pre-determined mitigation measures and resources to manage wildlife?

Yes

Section 9 Comments:

A wildlife mitigation plan was prepared by the Environment unit. Fencing was set up and wildlife control measures such as "hazing" took place under the direction of Unified Command (simulated).

SECTION C – POST EXERCISE

10.0 Post Exercise

10.1a Was a debrief meeting conducted that received input from all participants?
(CSA Z662-11 Clause 3.1.2(h) or 10.5.2.4)

Yes

10.1b Did the company describe how it will address participant feedback and lessons learned, the preparation of an exercise report, and how it will inform participants of the follow-up actions?

Yes

10.2 Were all documents collected after the exercise?
(CSA Z662-11 Clause 10.4.3.2 and 10.5.2.4)

Yes

10.3 Did the company evaluate whether the exercise objectives were met?

Yes

Section 10 Comments:

The Plains Midstream Canada exercise debrief meeting included a review of the follow-up processes for responding to lessons learned and participant feedback. An exercise report will be prepared that will include an action plan that will follow-up on feedback. The action plan will be implemented and tracked to completion. All documentation was collected after the exercise by Bissett consulting and the facilitators and participants were satisfied that the exercise objectives were accomplished.

SECTION D - NEB OVERALL OBSERVATIONS

The exercise met all pre-identified objectives and no non-compliances were identified by NEB Inspectors and Staff. NEB staff note that the competence of company personnel enabled an appropriate response to the exercise scenario.

Non-compliances?

No

SECTION  E - NEB SIGN OFF

NEB Staff: ______________________________
Date: ______________________________
NEB Staff: ______________________________
Date: ______________________________
Reviewed by NEB Senior Staff: ______________________________
Date: ______________________________

SECTION F - COMPANY SIGN OFF

Company Representative: ______________________________
Date: ______________________________