Compliance Verification Activity Report: CV2223-066 - Maritimes & Northeast Pipeline Management Ltd.

Overview

Compliance verification activity type: Emergency Response Exercise

Team:

• Inspector 2450

Regulated company: Maritimes & Northeast Pipeline Management Ltd.

Operating company: Enbridge Inc.

Province(s) / Territory(s):

• Nova Scotia

Discipline(s):

• Emergency Management

Rationale and scope:

<p><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">On 22 November 2022, a Canada Energy Regulator (CER) Emergency Response Exercise Evaluation Team (evaluation team) attended the Maritimes &amp; Northeast Pipeline (M&amp;NP or the Company</span><span style="font-size:10.5pt">) functional exercise in New Glasgow and Central West River, Nova Scotia. The evaluation team included 2 CER Inspection Officers. </span></span></span></p> <p><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">As indicated by the company, the exercise was focused on testing the functionality of the M&amp;NP response teams (Field Response Team &amp; Incident Management Team). This included:</span></span></span></p> <ul> <li><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">Use of the Incident Command System (ICS);</span></span></span></li> <li><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">Communication processes;</span></span></span></li> <li><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">Operational response management;</span></span></span></li> <li><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">Public affairs;</span></span></span></li> <li><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">Command and control of field response resources; and</span></span></span></li> <li><span style="font-size:11pt"><span style="font-family:Calibri,sans-serif"><span style="font-size:10.5pt">Tactical deployment of personnel for response operations.</span></span></span></li> </ul> <div> <hr /> <div> <div class="msocomtxt" id="_com_1">&nbsp;</div> </div> </div>

Compliance tool(s) used:

• None

Facility details

Facilities:

• Mainline

Facility Types

• Pipeline
• Meter station

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Plans And Procedures
• Emergency Response Plan (ERP)
• M&NP / Enbridge Emergency Response Plan(ERP): Core and MNP Annex

Observations (no outstanding follow-up required)

Observation 1 - # 1 - NS-2022-Mainline

Date & time of visit: 2022-11-22 08:00

Discipline: Emergency Management

Categories:

• Notification and Reporting
• Notification & Reporting as per EPM
• Communications
• Communications Equipment
• Organization of Stakeholders
• Coordination with Responders
• Safety
• Safety Plan
• Response Management
• Roles and Responsibilities
• Emergency Procedures Manual

Facility:

• Mainline (Pipeline)

Observations:

M&NP indicated that the goals and objectives of the exercise were to:

1. Demonstrate the ability to establish, maintain, and document safe initial response operations including the ability of response personnel to activate and maintain communications in accordance with the MNP Emergency Response Plan.
2. Prepare, Conduct, and Evaluate an ICS-201: Incident Briefing during the transition from Initial Response to Proactive Response.
3. Establish the appropriate structure under the Regional Incident Management Team (in-person and virtually) that can effectively meet the initial and long-term challenges required to mitigate the incident including the development of appropriate ICS forms for a simplified planning cycle.
4. Demonstrate the ability to keep appropriate stakeholders and the public informed of response operations through all phases of the response including appropriate internal communications and external notifications and ensuring consistent messaging throughout the response.

CER staff evaluated the following elements:

• Notification & Reporting
• Safety
• Response management
• Communications
• Interoperability with response agencies and organizations

Through CER staffs’ evaluation of the elements, goals, and objectives listed above, it was noted that the company response actions were executed according to the M&NP/Enbridge Emergency Response Plan (ERP): Core & MNP Annex.

CER staff observed M&NP staff demonstrate clear understanding of ICS and M&NP internal processes. It was also noted that M&NP staff took the opportunity to test multiple communication methods including cell phone, radio, and trunked mobile radios.

No non-compliances were identified during this exercise, however, CER observed opportunities to enhance efficiencies in the following areas: notification and reporting, interoperability with response agencies and organizations, and response management. See the corresponding Observations below. These opportunities will be considered by the Company and captured in the after-action report and/or improvement plan as appropriate by the Company.

Compliance tool used: No compliance tool used

Observation 2 - # 2 - Notification and Reporting

Date & time of visit: 2022-11-22 08:00

Discipline: Emergency Management

Categories:

• Notification and Reporting
• Notification & Reporting as per EPM

Facility:

• Mainline (Pipeline)

Observations:

CER staff observed that M&NP took the opportunity to use the “exercise” function in the online event reporting system (ERS) and promptly made the required notification to the CER. CER and M&NP staff discussed the value in continuing to use this function in future exercises but to also consider exercising the complete one window notification process between the CER and the Transportation Safety Board (TSB).

Compliance tool used: No compliance tool used

Observation 3 - #3 - Response Management

Date & time of visit: 2022-11-22 08:00

Discipline: Emergency Management

Categories:

• Response Management
• Response Priorities/Incident Objectives
• Incident Status Board

Facility:

• Mainline (Pipeline)

Observations:

CER staff observed that the tactics associated with completing each objective were not widely discussed or visibly displayed. CER staff note that exercise play was limited to the stem of the planning ‘P” and recognize that a formal tactics meeting was not within the scope of the exercise. However, CER and M&NP staff discussed the value of management by objectives and capturing the tactics and associated actions for each objective in some form (documentation, software etc.), even during the early stages of a response.

CER staff observed that appropriate ICS forms were prepared and posted. However, in some cases, dates and times were missing and/or the forms were not visibly maintained throughout the exercise. CER and M&NP staff discussed the value in ensuring the completeness of all documentation.

CER staff observed that it would have been beneficial to the exercise if discussion related to the access of the incident site (volume of snow and possible debris because of the snowstorm) was more detailed to help inform decision making and effective management of the response at the incident site. This aspect would have been clearer if the company involved third party stakeholders in the exercise, such as contractors (e.g., snow removal contractors).
 

Compliance tool used: No compliance tool used

Observation 4 - #4 - Interoperability with response agencies and organizations

Date & time of visit: 2022-11-22 08:00

Discipline: Emergency Management

Categories:

• Communications
• Organization of Stakeholders
• Coordination with Responders

Facility:

• Mainline (Pipeline)

Observations:

CER staff observed the Company automatically forming Unified Command with local response agencies. However, the Company did not demonstrate awareness of the CER’s potential role in their response and the expectation to form Unified Command and/or join the Incident Command Post/Emergency Operations Centre. CER and M&NP staff discussed the value in including CER staff throughout the exercise planning process and involving CER staff as exercise participants in future exercises.
 

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: