Compliance Verification Activity Report: CV2223-082 - SCL Pipeline Inc.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-082
Start date: 2022-12-19
End date: 2022-12-19

Team:

Regulated company: SCL Pipeline Inc.

Operating company: Shell Canada Products

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

On 19 December 22, a Canada Energy Regulator (CER) Emergency Response Exercise evaluation team attended the SCL Pipeline Inc. drill in Corunna, Ontario. SCL Pipeline Inc. is the certificate holder for the SCL pipeline (also known corporately as the Salmon A Pipeline or the MUST pipeline), which is operated by Shell Sarnia Manufacturing Centre. The evaluation team included two CER Emergency Management officers.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - CER Exercise Evaluation

Date & time of visit: 2022-12-19 13:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

On 19 December 22, a Canada Energy Regulator (CER) Emergency Response Exercise evaluation team attended the SCL Pipeline Inc. drill in Corunna, Ontario. SCL Pipeline Inc. is the certificate holder for the SCL pipeline (also known corporately as the Salmon A Pipeline or the MUST pipeline), which is operated by Shell Sarnia Manufacturing Centre. The evaluation team included two CER Emergency Management officers. 

The company indicated that the purpose of the exercise was to give hands on experience in responding to a pipeline emergency and in the required reporting. Their documentation listed the exercise objectives as:

  1. Identify Hazards – Demonstrate the ability to perform initial scene size up, identifying immediate hazards that pose risks to emergency responders and the public
  2. Manage risks – Demonstrate the ability to evaluate and prioritize risks to control probability or impact of incidents.
  3. Train and Manage Emergency Resources – Demonstrate the ability to respond to emergency situations and expand our training experience.
  4. Communicate Internally and Externally – Demonstrate the ability to communicate emergency messaging promptly and effectively both internally and externally.
  5. Manage Records and Documentation – Demonstrate the ability to manage incident records and documentation during and after an emergency event.
  6. Continually Improve Performance Demonstrate the ability to perform effective post incident debriefs, aspects of the emergency response that went well and those that did not.
  7. Meet our Reporting Requirements -Demonstrate to the CER our ability to response to a pipeline emergency and meet reporting requirements.

The initiating event for the drill was a leak on the pipeline near the road accessing isolation valve.  The simulated butane leak originated from a pressure gauge on the SCL pipeline.

CER staff evaluated the following elements:
SCL Pipeline Inc. used a phased approach in conducting the preliminary incident notifications: the online OERS report was filed a week in advance and the TSB numbers in the call down list was verified the day before the drill. This incremental approach can be useful for new response staff to learn about the CER regulatory notification process. CER officers heard that the company is creating a training tool to assist company staff in entering information in OERS. 

CER officers observed that the company Incident Commander (IC) referred to a notification checklist that was created for the exercise instead of the ERP. An opportunity for improvement identified by the company was to make such reference material available to responding staff by incorporating it as appendix to existing procedures. CER officers note that improvements to the notifications section of the ERP would also assist in reaching this objective.

Through an evaluation of the elements listed above and a review of the documentation provided, CER officers note that the company response actions were predominantly executed according to the SCL Pipeline Operated by Sarnia Manufacturing Centre Emergency Response Procedures.  Addressing the opportunities for improvement identified during the exercise debrief and after-action report will assist SCL Pipeline Inc in conducting a more effective response.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

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