SGA Awards recognizes successes in emergency management response.
CenterPoint Energy innovatively leveraged existing technology and datasets never before considered to predict customer leak calls before they were initiated. This represents the utilization of technology infrastructure investments in a new way that enhances our Emergency Management and restoration efforts and generates new value in our investment previously unrealized.
In August 2020, CenterPoint Energy’s Lake Charles, LA and surrounding territory was impacted by Hurricane Laura, a Category 4 hurricane at landfall with maximum sustained winds up to 150 mph. This storm damaged over 14,000 electric distribution poles, 300 substations, 225 electric transmission lines, and left over 550,000 electric customers in LA without power. 90% of the residents in our service territory were without power and most of the Lake Charles, LA area was without municipal utility services. This was the most impactful storm to this area since Hurricane Rita in 2005.
Prior to the storm, CenterPoint Energy conducted its pre-storm checklists to secure our system assets and facilities. The pre-storm activities also included reading meters of the areas anticipated to be impacted by the storm with our Automated Meter Reading (AMR) system. Among the obvious purpose to have a good read on meters prior to any damage, this also serves to provide positive acknowledgment of each meter on our systems immediately prior to the storm. Due to the storm’s potentially devastating impact to the area, CenterPoint Energy determined that the safest course of action was to evacuate personnel out of the area and to stage at an alternate facility.
Once the storm passed and it was safe to travel, CenterPoint Energy immediately began damage assessments and restoration efforts. Among the several assessment and restoration strategies, we deployed our AMR collector ahead of repair crews to collect meter readings and assess meters that could not be found and initiated service deactivation.
Due to widespread power and municipal utility outages, blocked roads, and lack of local services, many residents were not able to access or stay in their homes and commuted in/out of the area daily. While we had assessed and addressed nearly all urgent and emergency issues within a short amount of time, because the affected area still did not have power and local services, the Incident Commander was still concerned that there were residents that have not returned to their property to assess its condition. This potentially represented a number of customer houseline leaks that may be going unreported. Historically, these leaks would only be caught while performing work in the immediate vicinity and restoration personnel could hear or smell the leak, or if a customer/bystander called in the leak.
In addition to the meter index reading, the AMR infrastructure that CenterPoint Energy deployed also captures 15-minute incremental consumption data. Armed with this knowledge, the Incident Commander had the notion to utilize this data to potentially determine meters with uncharacteristically high consumption relative to the customer consumption history and to the pre-storm meter readings. The AMR department concluded there was sufficient data captured and began the analysis and developing the reporting necessary to establish high consumption. CenterPoint Energy also retains sufficient customer load information to exclude customers that have generators. Therefore, our AMR department was able to develop a list of active residential customers without generators that had uncharacteristically high consumption. Restoration personnel immediately began the investigation of each listed customer and found many with running generators. Additionally, this investigation proved valuable in that several were found to have had customer houseline leaks that contributed to the high-consumption data. In each of these cases, however, it was found that the homeowner or a concerned neighbor had already turned off the gas service at the meter. CenterPoint Energy was then able to properly and safely ensure that the service delivery was turned off and made safe.
While this inaugural use of AMR data to predict customer call-in leaks did not find active blowing customer leaks, this exercise proved the capability when there is inaction by the homeowner or concerned neighbors. CenterPoint Energy’s use of AMR data in this fashion was new and innovative and had not been previously considered. The AMR department was successful in developing the analysis and reporting to confirm and determine the customers with high consumption which directly translated to the prediction of customer call in leaks. This innovative use of data and technology will continue to be utilized to support future restoration or system stabilization efforts.
In February 2019, NiSource set a course to ensure it would be better prepared to meet the needs of any future incidents. A new Gas Segment Emergency Preparedness and Response (EP&R) team built a program from scratch, focusing on the learnings from the tragic 2018 Merrimack Valley incident as well as research and interactions with private and public stakeholders. The full-time, cross-functional EP&R team integrated improved preparedness plans and exercises covering a broad range of potential scenarios and levels of emergency.
Among the many steps the company has taken in building its program was the creation of a single EP&R Plan (EPRP) for the NiSource gas segment, with an accompanying Incident Command System (ICS) to ensure a clear command and control structure during incident response. The company’s ICS provides multiple backups for each role, ensures the ability to support a lengthy incident response and enhances our ability to interact with public safety officials and first responders. The EPRP and ICS provide clear guidance for communications to ensure the public and relevant stakeholders are appropriately informed in a timely manner.
The NiSource EP&R program has been recognized as an industry best practice by the American Gas Association (AGA), and team members presented during an AGA conference and best practices roundtable in 2020. EP&R team members were also invited to present at the Southern Gas Association’s Natural Gas Connect Conference in 2020, but due to the COVID-19 pandemic, the presentation was postponed until a future date.
We have received extensive feedback from multiple stakeholders including employees with ICS roles, and third-party training and exercise evaluators. The comments speak directly to the value of our program, and the successful outcomes we’ve realized since launching this effort just over two years ago.
Our program is based on a cycle of continuous improvement, and while we must continue strengthening our preparedness and response, we are proud of our progress and feel strongly that we are on the path to industry leadership.
In February 2019, NiSource significantly enhanced its Gas Segment Emergency Preparedness and Response (EP&R) efforts based on learnings from the Merrimack Valley incident in September 2018, and through research and interactions with private and public stakeholders. We built upon our existing efforts and created a full-time, cross-functional EP&R team to integrate improved preparedness plans and exercises covering a broad range of potential scenarios and levels of emergency.
Through ongoing training and regular exercises, the EP&R team provides awareness and understanding of all roles during an emergency to appropriate employees across the NiSource gas segment and corporate support teams. The goal is to ensure Incident Management Teams are capable of timely and effective response to incidents with potentially wide ranges of scale and complexity anywhere in NiSource’s service territory.
The first step was creating a single EP&R Plan (EPRP) that was implemented across the NiSource gas segment beginning on September 1, 2019. As part of this plan, the Incident Command System (ICS) was implemented to ensure a clear command and control structure during incident response. The company’s ICS provides multiple backups for each role, ensures the ability to support a lengthy incident response and enhances our ability to interact with public safety officials and first responders. The EPRP and ICS provide clear guidance for communications to ensure the public and relevant stakeholders are appropriately informed in a timely manner.
In building our plan and ICS, NiSource achieved the following objectives:
After forming in early 2019, our dedicated team of EP&R experts identified nearly 1,000 employees for roles in the ICS, launched a multi-year training and exercise program, and staffed a “Go Team” for rapid response to high-severity incidents. We continued to build upon this solid foundation in 2020 and are well-positioned for ongoing advancement and improvement.
The consulting firm Nixon & Associates provided benchmarking and independent analysis of our ongoing training and exercise program. Nixon & Associates is an emergency planning and crisis response firm based outside Washington, D.C., with more than 25 years of experience in the energy, utility and chemical industries. The firm was a key partner in exercises to identify and implement improvements.
Our training and exercise plan is robust but in its early stages, and it relies on a continuous, multi-year framework of training and exercises.
In late February and early March 2020, the EP&R team hosted in-person tabletop exercises for Columbia Gas companies in Virginia, Ohio, Massachusetts and Kentucky. Due to the COVID-19 pandemic, in-person exercises for Columbia Gas of Pennsylvania/Maryland and NIPSCO were postponed and conducted virtually via the webcasting platform WebEx in June and July, respectively. These exercises were designed to assess our performance when responding to Level 3 to 5 incidents and highlighted the increased capabilities of the organization, as well as areas of improvement, and were conducted while the ICS was active for our COVID-19 response. Nixon & Associates has provided an independent evaluation of the exercises, and those findings and recommendations are being incorporated into our EP&R plans.
The COVID-19 pandemic presented numerous challenges for NiSource and its Columbia Gas and NIPSCO subsidiaries. In addition to the safety, health, and operational concerns stemming from this situation, COVID-19 provided the first opportunity to implement a comprehensive, NiSource-wide response that incorporated lessons learned following the 2018 Merrimack Valley incident and the after-action reviews of incidents and exercises.
The company activated plans and personnel across its seven-state footprint at the local, state, and corporate levels. The pandemic response was managed by the ICS, and an Area Command was established to provide strategic guidance to Incident Management Teams (IMTs) in each state. These teams have responsibility for the local execution of response objectives.
The pandemic has impacted every aspect of our business, at every level of the organization, with more than 300 employees being activated for ICS roles in supporting the company’s COVID-19 response. Through its response to the pandemic, the company has expanded its foundational ICS knowledge and capabilities beyond the gas segment to utilize the ICS framework to guide a NiSource-wide response.
The response emphasized common terminology, consistent processes, appropriate safety protocols and strong communications. To date, the company has avoided a widespread outbreak of COVID-19 among its employees while experiencing no reported employee-to-customer or customer-to-employee transmission through hundreds of thousands of necessary interactions during the pandemic. In response to COVID-19, we engaged in a comprehensive, extended, multi-company utilization of both the ICS and the Area Command System. We achieved positive results, enhanced our engagement with local emergency management teams, and identified additional opportunities to learn and improve.
NiSource conducted an after-action review of the initial phase of the COVID-19 response. Based on feedback from hundreds of employees involved in the response, opportunities were identified regarding communication, process improvement and development, and clarity of ICS roles and responsibilities. The Area Command prioritized four findings from the after-action review and input those findings into the company’s Corrective Action Program (CAP) tool within our Safety Management System.
Similar to the tabletop exercises, Nixon & Associates provided an independent evaluation of the company’s initial COVID-19 response. Lessons learned from internal reviews and the Nixon & Associates evaluation are being incorporated into EP&R continuous improvement plans.
The NiSource EP&R program has been recognized as an industry best practice by the American Gas Association (AGA), and team members presented during an AGA conference and best practices roundtable in 2020. EP&R team members were also invited to present at the Southern Gas Association’s Natural Gas Connect Conference in 2020 but due to the COVID-19 pandemic, the presentation was postponed until a future date.
We have received extensive feedback from multiple stakeholders including employees with ICS roles, and third-party training and exercise evaluators. The comments below speak directly to the value of our program, and the successful outcomes we’ve realized in the little more than two years since launching this effort.
“The company’s embrace of, and extensive training on the ICS system, has greatly enhanced the organization’s ability to respond to emergencies. What’s more, the experience of working within the ICS structure – including establishing an Area Command Structure (ACS) to support the state-level ICS teams during the company’s response to COVID-19 — has supplemented the tabletop exercises as an additional training tool and reinforcement mechanism.” – Nixon & Associates, Assessment of 2020 Tabletop Exercises, August 2020.
“In the opinion of the evaluators, the exercise program initiated by NiSource is already among the best in its industry. While this analysis does find several “opportunities for improvement,” these relatively minor items should not indicate anything other than that the organization’s approach with its exercise program is on a solid footing. Further, the integrated exercise and training program effectively promotes the “continuous improvement cycle” sought to be organizations that are the benchmarks for effective emergency preparedness, planning and response.” – Nixon & Associates, Assessment of 2020 Tabletop Exercises.
“In the opinion of the evaluators, NiSource should be commended for continually “pushing the envelope” in its exercise program. With other operators and former clients, Nixon & Associates has noted a tendency to keep the planning and scope of exercises simple and within organizational “comfort zones.” Given the rapid development of its program, NiSource planners could easily have taken the approach of keeping the forward momentum of its program going by scripting a simple scenario “that sets us up for success.” The EP&R group notably moved away from such a mindset, and intentionally designed a “stretch scenario” with multiple layers of complexity in an effort to identify where the company needs to improve. In our opinion, this is rare and should be applauded.” – Nixon & Associates, Independent Analysis of Q3 2020 Functional Exercise, Sept. 8, 2020.
“Little did I know while going through the emergency response training on Friday that I would be using the principles 5 days later. I must tell you that it really helped to organize and safely address a situation that started yesterday afternoon. I really appreciate having gone through the training…Just wanted to pass this along on how valuable the training was to help manage the incident.” – NIPSCO Incident Commander (2019)
“The COH team participated in a gas segment ICS training exercise last week, which proved to be timely when the Wellington incident occurred just a few days later. The team was able to put their training to immediate use. This allowed for a smooth response and endeared us to our fire/police partners in Wellington.” – President, Columbia Gas of Ohio (2019)
“ICS helps everyone stay in their lanes with the jobs that need to be done, so the work on the ground can happen relatively uninterrupted. It allows us to do the needed work to keep our customers safe and get them back in service as quickly as possible.” –Vice President/General Manager, Columbia Gas of Ohio Deputy Incident Commander (2019).
“We recently implemented a planned ICS for the Merrimack Valley Service Line Verification Project. It allowed us to provide a common framework for the project which kept our resources aligned by setting clear and concise project goals. Without the ICS this project would not have been a success. During the planned project we did have an emergency where we had to swiftly shift the focus of the ICS team to the response and recovery efforts associated to the damage. Everyone knew their role and how they fit into the structure and got the job done. There were some hiccups, but like everything we do, we look back on what we did yesterday to improve for tomorrow.” – Columbia Gas of Massachusetts Incident Commander (2019)
At ONE Gas, we adopted API 1173 and Pipeline Safety Management Systems (PSMS) and made it our own by implementing the ONE Gas Safety Management Systems (OSMS) – consisting of 10 elements built on a Plan Do Check Act continuous improvement model. This model is an integral part of our Environmental Safety Health & Compliance (ESH&C) team’s governance program.
In 2018, with a focus on element 8, “Emergency Preparedness and Response,” we pivoted from responding to emergencies and began reshaping into an Integrated Emergency Management Program. An operational leader with extensive experience in this area was appointed as Director of Emergency Management and led this change.
The change began with a gap analysis – analyzing element 8 of API 1173, our regulatory requirements, internal practices, processes, programs, policies and procedures and our need to understand these two new terms “Unified Command/Incident Command Structures” and “external agencies and organizations”. The gap analysis revealed four areas that needed improvement.
We needed four new tactical plans in our Emergency Response Plan. These four areas have served us well in the last two years as the incidents we have experienced have touched all four: Pandemic, Security Threats, Loss of Utilities, and Civil Disturbances.
We needed to integrate Unified Command/ICS methodology into our procedures and our practices.
We needed to both participate in emergency management organizations where the “Whole Community” of Emergency Partnerships can be coordinated and be inclusive of them in our training and exercise programs.
We needed to refine our documents and processes of review and improvement for these activities to reflect the Plan, Do, Check, Act element of our OSMS. We needed Training and Development in an area that we had little experience – Homeland Security, FEMA, NIMS, and Incident Command Systems. Our Director of Emergency Management completed over 40 hours of FEMA/NIMS training both in classroom and online. He developed an internal training module for the field level employees and more in-depth training for the leadership team. It was particularly important for our company to retain our Gas Company Culture and be a Gas Company embracing Emergency Management and not an Emergency Management Agency that does Gas Company work. Our actions included:
Re-writing our Emergency Plan and related procedures, including a complementary Incident Command Systems Guideline.
Joining and participating in government-led emergency management agencies at the state, county and city levels and also their member associations of emergency partners at the regional and state levels.
Inviting emergency partners to participate in our training and exercises.
Developing an emergency response program that utilizes three categories. The program clearly identifies the roles and responsibilities of local operations and executive-level management. The program also outlines the activation criteria for each category. When the emergency response program reaches a category 1 emergency, the entire organization focuses on the incident and our senior executive team leads the management of the incident.
Developing and are refining documentation and processes to capture learning, developmental, and best practices from the engagement of emergency partners, exercises with them, and from the activations of our Emergency Response Plan.
On March 6, 2020, ONE Gas experienced its first COVID-19 case in Tulsa, Oklahoma. By the end of the next week, we activated our Pipeline Emergency Response Plan (PERP) to Level 2 and merged it with our cross-functional task force that was managing our Pandemic Plan. The activation of the PERP and the cross-functional team is still active today.
By embracing the FEMA/NIMS philosophy, we developed a four-level (Watch, Alert, Warning, and Critical) response plan based on the conditions, both internal and external, of our service areas. Each level corresponds to a different operational response. As our company advanced through the levels, we adjusted operations to minimize gas service disruptions, limit public and customer interactions, reduce resource requirements, and limit discretionary work in an effort to maintain safe and reliable natural gas service. Each level specifies the required PPE.
On March 16, 2020, we planned and initiated the process of transitioning nearly 50% of our workforce to a remote work environment. Our tentative Return to Office date is scheduled for September 7, 2021.
On March 7th, we engaged our injury case management and occupational health contractor – Axiom Medical. We elevated our program to a Medical Officer Review program to help us navigate through the COVID-19 Pandemic. We contracted with Axiom Medical to perform our employee COVID-19 protocol activated employee screening processes and have had more than 120% of our employee count inquires across the last 14 months. A personal screening application for smartphones was developed along with screening equipment and processes at our larger facilities. We acquired the proper COVID-19 PPE early and have not experienced a shortage of the required PPE to meet our protocols. We worked closely in all 3 states with our regulators to develop acceptable customer screening and response systems. Our Facilities have been reconfigured and marked, and we have developed new sanitization processes and equipped our facilities with newer HVAC air sanitization systems. For our employees, we added Paid Pandemic Leave to promote proper adherence to our new policies and procedures. We implemented a voluntary accommodation process for our vulnerable customer facing employees to take them out of harm’s way. We developed direct lines of communications with our 3 state’s departments of emergency EOC’s, Department of Health Agencies, and initiated and hosted one on one meetings with the leadership of the Vaccine Teams in all three states.
On February 9th and extending through February 19th the ONE Gas service territory experienced a historic and unprecedented 11-day long period of extreme and record-breaking cold weather. The cold air system led to the coldest air in decades across the Southern States, reaching all the way to the Rio Grande Valley, bringing crippling amounts of snow and ice to Kansas, Oklahoma, and Texas for an extended period.
During the event, we simultaneously experienced constrained supply and increased demand resulting in substantial challenges for system reliability. Curtailment plans were implemented. Customers were encouraged to conserve energy. Despite the challenges, less than 1,000 customers out of 2.2 million customers experienced loss of service during the event.
The Crisis Management Plan was activated on February 13, 2021, at 4:00 pm. On February 23, 2021, at 7:30 am, the Crisis Management Team determined that the situation had stabilized and deactivated the Crisis Management Plan