Compliance Verification Activity Report: CV2021-072 - Enbridge Pipelines Inc.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-072
Start date: 2021-01-27
End date: 2021-01-27


Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):


Rationale and scope:

**Postponed due to COVID-19** Evaluate an exercise to verify response capabilities as per the condition. Exercise scheduled for 20 May 2020 has been rescheduled to the 27 January 2021.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Additional Project-specific requirements or conditions:

Condition 35 a, b, c

Observations (no outstanding follow-up required)

Observation 1 - Exercise Evaluation

Date & time of visit: 2021-01-27 09:00

Discipline: Emergency Management




Exercise Planning and Conduct
An Emergency Response Exercise Evaluation Team of the Canada Energy Regulator (CER) attended the Saskatchewan Line 93 table top exercise (TTX) hosted virtually by Enbridge Pipelines Inc. (Enbridge) on the 27th of January 2021. The team included CER Inspection Officers and other emergency management staff and a Line 3 Indigenous Advisory and Monitoring Committee (IAMC-Line 3) Indigenous Monitor. 
The exercise was conducted to support the company’s Emergency Management Program requirements as per s.32 of the CER Onshore Pipeline Regulations and for compliance to Condition 35 (a) of Order OC-063 requiring that an exercise specific to this line be conducted in Saskatchewan.   This exercise was the second of three exercises to be held in relation to Condition 35. The previous exercise, a TTX, was held in Alberta in fall 2020.  The final exercise, a full-scale, is schedule for spring 2021. 
An Exercise Plan and Player’s Card were available and shared with attendees and the CER before the exercise.
The exercise and training delivery was facilitated by a contractor, The Response Group (TRG), on behalf of Enbridge.  The majority of exercise participants were Enbridge staff.  Some TRG staff were directly involved in the exercise providing Incident Command System (ICS) support to Enbridge staff. The exercise included a large number of observers, including invited representatives from the Saskatchewan Public Safety Agency, Saskatchewan First Nations, the Métis Nation–Saskatchewan, the IAMC-Line 3 as well as first responders from local emergency services and the Royal Canadian Mounted Police. 
The exercise began with familiarization for staff of the computer application that would be used to conduct the response.  Facilitators from TRG were available to offer additional help. 
The purpose of the exercise was to test and practice oil spill emergency response and procedures for Enbridge’s Line 93 pipeline.
The scope of the exercise focused on the initial phase of an emergency response following a liquids release. 
The exercise objectives were:

The Evaluation Team verified that emergency processes and procedures were utilized during the training exercise.  The documents followed by company staff covered safety, communications, and system operation procedures for use during emergencies.
The exercise was conducted in a virtual environment (software application). Before the official start of the simulation, TRG provided familiarization training on the virtual environment and a high-level orientation to the Incident Command System.  The company Exercise Director then delivered an overview of the exercise plan with the approximately 104 attendees.   
Notification and Reporting

External notifications were part of the scope of this exercise and were both discussed and simulated or conducted as the scenario developed.  External notifications to Indigenous Nations were conducted in accordance with Enbridge’s Unplanned Release Notification Protocol for Indigenous Nations.  Notifications were successfully completed for 14 of 16 Indigenous Nations, within 1 hour, as per the protocol.  All other external notifications, except to the Transportation Safety Board (TSB) and CER, were simulated. 
Regarding notification of the CER, Enbridge staff called the TSB to report the incident, who in turn, called the CER as per established process.  Enbridge staff subsequently entered the incident in the CER’s online event reporting system (OERS). 
Internal notifications were accomplished as prescribed in the appropriate company manuals and protocols. See section below on Communications. 
Safety of participants was discussed at the beginning of the exercise. As this was a virtual exercise, no PPE or related field safety equipment was required.   The safety of company staff who would have been in the field in a real event was discussed at every stage of the exercise, including COVID-19 safety and mitigation.
The Safety Officer was accountable for the safety of responders and the public and initial safety procedures and protocols were established and communicated. Work was also initiated on a longer term incident-specific safety plan. The Safety Officer participated in Command and General staff meetings as appropriate.
Public protection was a priority of the response and a local landowner in the vicinity of the spill was evacuated and accommodated at a local hotel. An air monitoring plan was one of the first tasked assigned to responders.  Simulated road blocks were established as the release site was in close proximity to a major highway.
Response Management
ICS roles were assigned at the start of the exercise by the Incident Commander (IC).  Enbridge staff used colour coded and labeled video backgrounds in the virtual software during all communications.   
The simulated scenario initiated with a leak detection alarm indicating a potential release in the Odessa to Glenavon station area of Enbridge’s Line 93 in Saskatchewan.  The company control centre initiated shutdown and activated its Regina Pipeline Maintenance Team (PLM) to confirm a release. Upon confirmation of a release into a partial snow covered slough, the Prairie Region Director activated the Incident Management Team.
Internal notifications were conducted and external notifications were discussed, planned and executed.   
Channels in the virtual software were used to simulate the tables and sections in a physical ICP.  Various meetings with all participants were held in the general channel and command staff and section or unit meetings were held in separate channels.  Enbridge had incorporated feedback from the Line 93 TTX held in Alberta in November 2020 by adding specific or additional channels for all of the Command Staff or for specific break-out meeting.  At the end of the exercise, participant feedback indicated that this was a useful improvement and CER staff agree.
In addition to the virtual software used for the exercise, company participants also had specific emergency management software to document and track response action as per established ICS protocols.  These participants shared their screens when using the response software to the positive benefit of co-participants and observers.  It should be noted this was an improvement over the previous Line 93 TTX held in Alberta in November 2020.
CER staff observed several meetings and break-out meetings and noted participants discussing documents, working on ICS forms (in the response software), and sharing information.  Meeting schedules and timings were clearly communicated early on and throughout the simulated response.  These more visible activities were an area identified for improvement by exercise participants following the Line 93 TTX held in Alberta in November 2020, and subsequently implemented in this exercise.
Participants were instructed to follow the Enbridge Integrated Contingency Plan - Prairie Region, the Enbridge Field Emergency Response Plan - Prairie Region, and the Enbridge incident manual handbook. CER Staff observed that staff were following these company documents and discussing their contents.  Maps and system diagrams were available and used by responders.   
The ICS roles established followed those identified in the Company’s ERP. The exercise used ICS documentation to develop a 201 briefing package. 
During early stages of the exercise, multiple participants noted the potential for confusion when operating across two time zones (Mountain and Central).  Simple and immediate mitigations were identified and implemented.  These included an early decision to communicate all times in Central time, to clearly annotate time zone (CST) on documentation and schedules, and a recommendation for staff working in Mountain time to temporarily change the time zone setting on their computers.
Response Tactics

Following activation, the IC immediately tasked staff to identify the proper environmental notifications for the province.  The IC also dispatched operators to the site and system shutdown procedures were commenced.  Many potential response tactics would require the completion of the resource at risk summary which was started in the exercise but in a real event would be completed with the assistance of a third party contractor. 

Indigenous notifications were also a key part of the exercise and potential impacts to Indigenous cultural resources were evaluated.  
While the exercise only covered the initial hours of a response, participants still planned for a week-long response and activated resources accordingly, including establishing the Incident Command structure for the later phases of the response.  

As per the Line 93 TTX held in Alberta in November 2020, CER staff observed that Enbridge effectively demonstrated a “get big quick” strategy by ordering and coordinating a significant amount of operational spill response resources from both within Enbridge and via third party contractors.   

Trajectory mapping was completed and shared with participants and observers.  This map was displayed as a layer in a GIS based portion of the response software mentioned previously, in addition to other layers such as location of the PLM, deployed resources and first responders on-site. 

An environmental specialist was inserted directly in the Operations Section. CER staff note that this person played a valuable role in informing response tactics and liaising with the Environment Unit. Enbridge staff also noted the value of having an environmental specialist within Operations during the early hours of an incident.

Additional tactical considerations included creating a medical plan including COVID-19 precautions, making additional funds immediately available to assist field staff on their arrival, and staffing an Indigenous Liaison Office.

CER staff observed Enbridge staff managing the emergency situation from start to finish in a technically and professionally sound manner.

CER staff observed that Enbridge staff effectively communicated during the exercise. CER staff observed more open sharing of important 56t5 information amongst participants than in the previous TTX.   
CER staff observed that an observer channel in the virtual meeting space was not heavily used as observers chose to use the channels being used by responders instead. CER staff observed robust discussion and information sharing in the Indigenous Liaison channel.
Participants worked on a draft media plan in real time. 
Post Exercise
Overall, CER Staff are of the view that the TTX objectives were met. The training completed was in line with a TTX. The participants had productive discussions and demonstrated what they would be doing as it related to the exercise scenario.
CER staff note that the TTX was realistic and representative of potential hazards and risks associated with the Line 93 pipeline. 
As noted under Response Tactics, the company “went big quick” in its approach to requesting and mobilizing resources. CER staff note that this is a generally accepted principle of effective spill response.
During the course of the exercise, Enbridge staff noted the value of including Control Centre Operations (CCO) in the exercise as opposed to just simulating the CCO through the exercise’s Sim Cell.  This was an area for potential improvement identified by exercise participants following the Line 93 TTX held in Alberta in November 2020, and subsequently implemented in this exercise.
Enbridge staff noted the positive contribution of an environmental specialist working directly in the Operations section as noted under Response Tactics. CER staff agree.
 CER staff observed that the hosting of observers by a knowledgeable guide would likely increase the education value of the exercise.
Enbridge staff noted that they found the training helpful and appreciated the support from TRG, and that they observed an improvement in support provided by the Indigenous Liaison Office as compared to the previous exercise.   Enbridge staff also said that additional legal and logistical participation added to the realism of the exercise.
During the exercise, Enbridge staff discussed the benefits of the virtual environment/software platform and discussed its potential benefits in a post-pandemic response environment.  CER staff agree that these types of virtual capabilities have potential benefit in a post-pandemic operating environment.
CER staff noted that while experienced responders and Emergency Management specialists may have understood that the exercise played out faster than it would have in a real event, it would have been beneficial to discuss real timelines at the start or finish of the exercise for co-participants and observers.    

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