Program Description
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.
2019 – Building a Solid Foundation
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:
- Completed best practice visits externally with gas industry peers and internally with the Northern Indiana Public Service Company’s (NIPSCO) electric storm team.
- Adopted the ICS as recommended and used by Federal Emergency Management Agency (FEMA) and other companies and agencies and established a structure with multiple backups for each role. This helps ensure our ability to support sustained incident response and readiness. Having a complete roster with trained backups provides depth if an employee with primary responsibility is unavailable.
- Reviewed and analyzed existing corporate and NiSource operating company Emergency and Crisis Communications Plans and Business Continuity Plans and ensured their alignment with our Emergency Preparedness and Response Plan.
- Outlined consistent definitions for incident levels from less severe (Level 5) to the most severe (Level 1) to align with the American Petroleum Institute’s Recommended Practice 1173, which is industry best practice.
- Mandated annual computer-based, emergency preparedness and response training for every NiSource employee (approximately 8,000) – whether directly involved in the ICS or not.
- Developed and began executing on a multi-year training and exercise program to include enhanced training for employees with ICS leadership roles. Training includes computer-based course work, instructor-led position-specific coaching sessions, Command and General Staff self-study workbooks, ICS training scenarios and tabletop exercises. This training and exercise program is part of a comprehensive approach reviewed by an independent, expert third-party evaluator. The enhanced training builds employee familiarity with the plan and its processes and terminology while ensuring employees more deeply understand their roles and responsibilities. It also emphasizes the importance of strong relationships with external stakeholders.
- Facilitated the successful completion of classroom training and certification in FEMA ICS 100, 200, 300, 700 and 800 modules for members of the EP&R team.
- Established a “Go Team” of approximately 20 highly skilled, highly experienced employees to serve, as needed, for the most severe or catastrophic Level 1 and Level 2 incidents. The team will be activated for a Level 1 or Level 2 incident in any of our states, if needed, as supplemental resources or backups for all ICS positions. This cross-industry best practice ensures that a core group of leadership is ready and trained to quickly engage in a significant incident. In early December, this “Go Team” participated in a tabletop exercise followed by an intensive 21-hour, instructor-led training course FEMA ICS 300: Intermediate Incident Command System for Expanding Incidents.
- Ordered custom-built Mobile Command Centers to strengthen our ability to efficiently, effectively and safely respond to incidents, while also supporting training exercises across our service territory. Each 38-foot trailer will be strategically located to allow for rapid deployment and the least amount of travel time.
2020 – Maintaining the Momentum
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.
Tabletop 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.
COVID-19 Response
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.
Results/Response to the Program
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.
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“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.
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“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.
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“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)
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“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)
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“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).
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“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)
