Compliance Verification Activity Report: CV2021-490 - NorthRiver Midstream G and P Canada Pipelines Inc., as general partner and on behalf of NorthRiver Midstream G and P Canada Pipelines Limited Partnership


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-490
Start date: 2020-10-28
End date: 2020-10-28


Regulated company: NorthRiver Midstream G and P Canada Pipelines Inc., as general partner and on behalf of NorthRiver Midstream G and P Canada Pipelines Limited Partnership

Operating company: NorthRiver Midstream G and P Canada Pipelines Inc., as general partner and on behalf of NorthRiver Midstream G and P Canada Pipelines Limited Partnership

Province(s) / Territory(s):


Rationale and scope:

To verify compliance with the OPR. Attend a virtual TTX to evaluate a company we have not seen conduct an exercise. The scenario will be based on a CER pipeline leak in the Tupper Main area.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Table Top Exercise Evaluation

Date & time of visit: 2020-10-28 09:00

Discipline: Emergency Management




Exercise Planning and Conduct
An Emergency Management Exercise Evaluation Team of the Canada Energy Regulator (CER) attended a table top exercise hosted virtually by NorthRiver Midstream G and P Canada Pipelines Inc (NorthRiver) on the 26 of October 2020. The team consisted of an Inspection Officer (the Officer) and an Emergency Management Specialist. The exercise was conducted to support the company’s annual Emergency Response Plan (ERP) update process as part of its Emergency Management Program requirements as per s.32 of the CER Onshore Pipeline Regulations. An Exercise Plan was available and shared with the CER before the exercise. Other attendees included company participants and facilitators.
The exercise included NorthRiver’s Tupper Main and Tupper West Operations Support Personnel and management.  A representative of the BC Oil and Gas Commission was also present as the exercise was held to satisfy response preparedness requirements of both regulators.  The purpose of this exercise was to evaluate the company’s ability to respond to an emergency incident and to improve its South Peace ERP.  The exercise objectives included familiarization with the ERP to build confidence and preparedness, to demonstrate operational capability, to reveal resource gaps, and to meet regulatory requirements using a remotely facilitated training session due to Covid19 restrictions.       
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 mainly held virtually however some participants where on site at NorthRiver’s facilities.  These participants used teleconference equipment while most used a computer based application as the CER staff did. Participants were given the initial scenario as a group and asked to talk through the initial steps in responding to the simulated incident.  ICS Roles were assigned and the ICP staffed and initial tasks identified.  Several further injects were provided to the group by the facilitator to simulate a more challenging scenario. 
Notification and Reporting

External notifications were part of the scope of this exercise and were both discussed and simulated as the scenario developed.  The notification of outside stakeholders was discussed to have included; the TSB and CER, EM BC, BCOGC, AER as a courtesy, and first responder and town officials.
Internal notifications were accomplished as prescribed in the appropriate company manuals, 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.  Public protection was the number 1 priority of the response.  Also, several injects related directly to the safety of nearby residences were used to train staff to consider and ensure protection of the public during a pipeline incident response. 
There was also discussion of Covid19 protocols and photos were shared with the Officer that indicated masks were worn in the ICP by the majority of participants.
Response Management
The exercise began with some familiarization for staff of the computer application that would be used to conduct the response.  Facilitators were available 30 minutes early to offer additional help.  It should also be noted that no first responders were included in the exercise due to current pandemic restrictions. 
The simulated scenario was initiated with a call received from landowners who discovered a release.  The company’s ERP was activated, operators dispatched to site and initial response actions from the ERP were implemented by the initial Incident Commander (IC).  Once additional internal notifications were made, a more senior IC was assigned who then commenced ICS role assignment.  
Once the ERP task called “planning for notifications” was completed, initial onsite actions for company responders were discussed in advance of their arrival in the field.  In addition, consideration of mutual aid agreements and public protection measures such as road blocks and traffic control were also discussed.  The Officer noted that staff were following their company ERPs.  Maps and system diagrams were available and used by responders.   Throughout the exercise additional injects were used to offer challenging and unexpected hazard considerations to provide a level of realism. 
The ICS roles established followed those identified in the Company’s ERP and Emergency Response Program. However, according to the ICS organizational chart shared with CER staff, the ICS span of control principle (no more than 7 direct reports) may have been exceeded by the IC by 1. The exercise used ICS to develop a 201 briefing package as the training events main output.  This package was shared with CER staff following the completion of the exercise.  Most of the package was completed, any sections not completed were briefly discussed during the exercise debrief.   
It was observed by the Officer that ICS forms and visual tools would have added more value to the management of the response if they were posted in the virtual response space for the participants to see, use and for collaboration.  For instance, use of ICS vests in the ICP and ICS colour coded backgrounds in the virtual meeting software to visually identify individual positions.

Response Tactics

(The following is a description of the response actions and tactics that were simulated during the exercise discussion)
Following the incident notification by landowners, the IC immediately dispatched operators to the site and commence system shutdown procedures.  Road blocks and traffic control measures were established to protect the public.  Air monitoring was simulated to be deployed with Lower Explosive Limit (LEL) verification conducted. The level of emergency was assessed and internal and external notifications were treated as a priority.  A mutual aid agreement was activated with another company and a reception center set up for an impacted residents.
Following an inject related to landowner’s health a helicopter was requested for a medical evacuation and hazards to air operations discussed monitored.

Once operators arrived on site they established zones of control, assisted the landowners, and isolated valves. At the appropriate stage the emergency classification was lowered.

Later in the exercise a distracting inject with potential security implications was introduced and the response team stayed focused on the task at hand and kept to the predetermined incident priorities.  Through discussion, it was determined that proper scene isolation and notification to authorities could take place without altering response tactics.   

Overall, CER Staff observed NorthRiver staff managing the emergency situation from start to finish in a technically and professionally sound manner.


Overall, NorthRiver staff effectively communicated during the exercise. The Officer however observed that those calling into the exercise by telephone were hard to hear.  As mentioned above, more use of the computer application features to post visual materials would have been more effective in terms of keeping all participants aware of strategies and tactics.   
Internal notifications procedures were activated as well. However, a greater portion of the simulated exercise involved communication with the two participating regulators being the CER and BCOGC.  The IC confirmed with the BCOGC before lowering the emergency classification level. 
Post Exercise
Overall, CER Staff are of the view the table top exercise objectives were met.  However, both CER staff in attendance noted that the amount of objectives were more than usual and training value would have benefitted from simple and clear goals for all participants.
The training completed was in line with a table top exercise. The participants had productive discussions and completed a walk through or a talk through of what they would be doing as it related to the exercise scenario.
CER Staff note that the 3 hour table top exercise was, realistic, hazard driven and effectively accomplished all objectives set forth by the facilitator. However, the Officer notes that the timed objectives may have kept the pace too fast to fully complete all ICS documentation and for all participants to be engaged equally.
Participants were energetic and engaged and there was ample discussion of all tasks and related injects using PPOST as a practice.  PPOST is an ICS tool for categorizing incoming information during an emergency. PPOST stands for priorities, problems, objectives, strategies, and tactics
CER staff made the following recommendations:


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