Compliance Verification Activity Report: CV2122-009 - Alliance Pipeline Ltd., as General Partner for and on behalf of Alliance Pipeline Limited Partnership


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-009
Start date: 2021-10-21
End date: 2021-10-21


Regulated company: Alliance Pipeline Ltd., as General Partner for and on behalf of Alliance Pipeline Limited Partnership

Operating company: Enbridge Alliance (Canada) Management Inc., in its capacity as Physical Services Operator

Province(s) / Territory(s):


Rationale and scope:

Follow-up to verify that the company has incorporated learnings from a past exercise into their procedures. Full scale exercise scheduled for October 2021 in Gordondale, AB. As a result of areas of improvement identified during the 2021-494 exercise and subsequent changes to their procedures and processes, Alliance should evaluate the adequacy and effectiveness of its procedures and processes and document corrective and preventive actions if deficiencies are identified. Currently this exercise will be in-person to test and evaluate the company's emergency procedures manual (EPM).

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Emergency Response Exercise Evaluations - BC/AB Gathering Area Full-Scale Exercise

Discipline: Emergency Management




Exercise Planning and Design, Facilitation, and Control
On 21 October 2021, three Canada Energy Regulator (CER) staff attended the Alliance Pipeline Ltd.’s (Alliance or the Company) BC/AB Gathering Area full-scale exercise in Gordondale, AB. There were no external parties in attendance at the exercise however invitations to participate were extended to local first responders. All external agencies were simulated by exercise controllers.

The exercise scenario focused on a response to an escalating security incident and involved discovery of a suspicious device placed on the mainline inlet piping at the Blueberry Hill Compressor Station. A field technician arrived onsite and found the vehicle gate open, the lock cut, and a suspicious package was clearly visible on top of the pipe.
The exercise was comprised of three areas:

CER staff requested and received an exercise participant package prior to the exercise date. This package included exercise purpose, scope, timetable, control, scenario narrative, objectives, safety, COVID-19 protocols, field gathering area specifics, Calgary office and EOC specifics, debrief and ground rules that covered the field gathering area, exercise termination, communication, and the simulation centre. Orientations were held with participants and observers prior to the exercise to go over the contents of the participant package. CER staff note that this expedited the introduction and exercise kick-off process and allowed for exercise play to begin right away on the day of the exercise. An Alliance orientation was also conducted just prior to exercise play to familiarize CER staff with applicable Alliance policies, site orientations and procedures.

The exercise objectives, as identified below, were attainable, measurable, and realistic for the exercise. The scenario was designed in consideration of the hazards and risks posed by the company's operations. Exercise control was sufficient for the size and scope of the exercise and appropriate injects were adequately progressed throughout the scenario.

Exercise Objectives:
1. Identify and use the Area Security Response and Awareness Procedures (ASRAP).
2. Demonstrate the ability to conduct safe response operations using emergency response resources in accordance with the British Columbia / Alberta Gathering Area Emergency Response Plan.
3. Complete ICS 201 form documentation and complete an incident briefing.
4. Review and document the initial notification procedures for all internal and external stakeholders.
5. Development of a public holding statement and initial communications plan

CER staff are of the view that objectives were partially met, given that the ICS 201 form was not fully utilized, completed or available for use during incident briefings. 

Notification and Reporting
The Company activated its response in accordance with its emergency procedures manual (EPM). CER staff observed that Alliance staff initially classified the incident as a Tier II response and later upgraded to a Tier III as more information became available. Other notifications, such as to municipal and indigenous communities, were conducted as per the EPM. However, in regards emergency services notifications, CER staff noted that it was unclear to staff in the field ICP when 911 was called and notifications to the RCMP and Fire Department appeared to occur at separate times as the Fire Department did not arrive until much later than the RCMP. CER staff note that the arrival times were a part of the exercise design. However, CER staff are of the view that communicating the timing of when the notifications to emergency services (911) occurred remains important information for the field to receive. This would alleviate confusion in the field, help to avoid repetition - such as the field calling 911 again - and facilitate the dissemination of information. 

While courtesy notifications were made to the Transportation Safety Board and the CER, this type of incident is not immediately reportable. Upon confirmation of a reportable release all regulators were notified according to the CER’s Event Reporting Guidelines requirements for immediately reportable events.

Following the initial observation of the open gate and facility lock being cut, Alliance staff did a quick scan to identify any anomalies before leaving the premises. Alliance staff then made use of equipment available to them in their vehicles, such as binoculars, to attempt to identify the concern without getting too close. Once confirmation of the threat was made, field participants evacuated to a safer distance approximately 400 metres from the site. As more information became available and as potential impact radius (PIR) calculations were made, ICP participants moved further back in accordance with the EPM. CER staff noted an improvement in the safety of the approach taken during initial incident identification than was observed in a previous exercise, CV2021-494.
CER staff observed that product specific information and characteristics were not made readily available or openly discussed at the ICP. However, it was observed that Alliance staff were aware of the product and its characteristics and appeared to respond with appropriate tactics and strategies. CER staff discussed with Alliance staff that if other agencies or external parties are present, product specific (potential) hazards and threats must be clearly discussed.

Response Management / Tactical and Strategic Response
Incident Command System (ICS) was used, and Company staff appeared to follow the basic elements and principles. CER staff observed that Company staff adapted to the changing conditions of the scenario and the assigned response roles were consistent with its EPM. CER staff observed that there was no visible identification of roles at the ICP. For this scenario, the limited number of personnel in the field prevented this from being a problem, however, a larger incident or one with external parties present would require some form of identification to achieve effective response coordination. CER staff observed that in the EOC, vests were distributed at the onset of the incident and each section had role specific kits containing the specific forms/supplies required.

CER staff observed that while Alliance staff at the ICP were diligent with taking individual notes throughout the incident, ICS forms were not completed until later in the incident.  As one of the objectives was to complete the ICS 201, CER staff are of the view that this form should’ve been started immediately and maintained throughout the incident to ensure successful completion of the objective. A completed 201 also would have been beneficial in facilitating an expeditious briefing of incoming resources, both internal and external (RCMP, Fire Department). CER staff observed that ICS forms were used in the EOC from start to finish of the incident. However, there was confusion between the ICP and the EOC as to who would be filling out the ICS 208 Initial Health and Safety Plan so this form was left until left until later in the incident. Being a Health and Safety Plan, this form should not be delayed in being populated and implemented. Due to the late start of the use of ICS forms in the ICP and the confusion between who would be filling out each form, CER staff observed that additional training on ICS forms and conducting field briefings would better facilitate the dissemination of information and contribute to a safe and efficient response.

A formal meeting schedule was not posted but check in times and next meeting times were well communicated verbally. However, CER staff observed that ICP updates to the EOC occurred every half hour which did not allow for work to get done in between meetings.
CER noted that it was very difficult at times to hear what was happening at the ICP.  Better facilities (speakers or a number to dial in) would help participants to be able to better communicate while working from their vehicles onsite. CER staff noted that COVID-19 distancing requirements also factored into this difficulty as staff had to remain 6 feet apart.

CER staff noted good two-way communication between the ICP and the EOC when determining appropriate strategies and tactics. CER staff at the ICP observed limited advanced planning; such as establishing operational periods, discussing resources for a nightshift/extended response, or contingency planning for extinguishing immediate and secondary fires. CER staff note that the exercise was limited to initial response and did not include additional operational periods. However, planning considerations, such as clearly identifying and communicating the initial operational period, would have added an appropriate level of realism to the exercise.  

Response Communications Technology
Cell phones, radios and MS Teams were identified as the primary methods of communication. Radio frequencies were identified and communicated by the field incident commander. As noted above, CER staff observed minor challenges with communication methods which included connectivity and Bluetooth concerns.

Participants from the Company’s Legal Department encouraged responders to utilize Teams chat rather than phones so participants could be privy to all communications as well as to assist with information audits post incident.

External Communications
Communications with first responders and stakeholders were simulated. Alliance staff made use of pre-written media cards from its EPM and a more detailed holding statement was developed for release once all internal and external notifications were complete. A 1-800 number was established to assist Gas Control in managing the influx of calls from sheltered and other concerned members of the public.

Public Protection
Area landowners were identified, and residents were advised to shelter in place. As the situation evolved and the PIR increased, the ICP adjusted its position as required. CER staff heard that an evacuation centre was identified and Alliance staff had calculated a potential of 12 evacuees. This number covered the residents within and immediately outside the PIR. However, CER staff at the ICP did not observe if discussions on how/when to evacuate any impacted residents occurred.

Roadblocks were established east and west of the incident site. CER staff observed that Company staff at the ICP identified the area as being used recreationally, and that atv/utility terrain vehicles, hikers, farmers, and hunters could be present in the vicinity. CER staff did not observe how Alliance staff planned to mitigate this potential issue, however it was also noted that recreational users in the area were not included in the scope of the exercise. 

Emergency Operations Centre (EOC)
CER staff were unable to access the EOC within the MS Teams platform due to Alliance’s information technology limitations. Attending in person for this scenario mitigated any potential issues in this case. However, should the intent be to use a hybrid or virtual EOC moving forward Alliance will need to ensure that that the CER and other applicable regulatory agencies can be granted full access (if requested) for all future exercises and real incidents.

CER staff observed that Alliance was able to effectively respond utilizing a hybrid EOC model allowing for both in person and virtual participation. However, it was noted that more familiarization with the EOC set up and applications would be beneficial as the monitors and other available technology were unable to be used with the MS Teams platform. CER staff noted clear communications, and methodical and efficient task delegation. An ICS status board was maintained during the exercise. The Planning section’s work was delayed by having to continually run upstairs to print and copy required documents. To achieve a timely response, it would be beneficial to have resources, such as printers and other relevant supplies/equipment, available directly in the EOC.

Post Exercise
Following the end of the exercise an exercise debrief was held. The debrief collected feedback from all participants and observers and was recorded to identify opportunities for improvement and to track action items.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Alliance Pipeline Ltd. is requested to file an after action report.
Follow instructions in the Documents section to upload and submit the AAR by 18 February 2022. The AAR should describe:

The AAR should also include improvement planning such as a corrective action plan (CAP), that identifies program improvements and the necessary corrective actions required to address them, and an improvement plan, identifying the corrective actions to be taken, the responsible party or agency, and the expected completion date.

Due date: 2022-02-18

Date closed: 2022-02-18
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

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