Compliance Verification Activity Report: CV2223-052 - Genesis Pipeline Canada Ltd.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-052
Start date: 2022-10-12
End date: 2022-10-13


Regulated company: Genesis Pipeline Canada Ltd.

Operating company: Nova Chemicals Corporation

Province(s) / Territory(s):


Rationale and scope:

<span style="font-size:12pt"><span style="font-family:&quot;Times New Roman&quot;,serif"><span style="font-size:10.0pt"><span style="font-family:&quot;Arial&quot;,sans-serif">On 13 October 2022, a Canada Energy Regulator (CER) Emergency Response Exercise evaluation team attended the Genesis Pipeline Canada Limited (GPCL) exercise in Corunna, Ontario. GPCL is the certificate holder for the pipeline, which is operated by Nova Chemicals. The evaluation team included three CER Inspection Officers representing Emergency Management, Pipeline Integrity, and Safety teams. A CER Engagement Specialist was also in attendance to observe the exercise.&nbsp; </span></span></span></span>

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - CER Evaluation of Genesis Pipeline Canada Limited Emergency Response Full Scale Exercise

Date & time of visit: 2022-10-13 14:00

Discipline: Emergency Management




As stated by the company, the purpose of the exercise was to establish and maintain close working relationships with agencies that may be involved in an emergency response on a pipeline. The objectives identified by Genesis Pipeline Canada Ltd. were:

  1. Demonstrate the ability to perform initial scene size up, identifying immediate hazards that pose risks to emergency responders and / or the public.
  2. Demonstrate the ability to evaluate and prioritize risks to control probability or impact of unfortunate events
  3. Demonstrate the ability to work with external emergency response agencies as Unified Command within ICS/IMS.
  4. Demonstrate the ability to promptly & effectively communicate emergency messaging both internally and externally.
  5. Demonstrate the ability to effectively manage incident records and documentation during and after an emergency event
  6. Demonstrate the ability for Unified Command to track progress and facilitate effective decision making
  7. Demonstrate the ability to perform effective post incident debrief aspects of the emergency response that went well, and those that did not.
The initiating event for the exercise was a pipeline overpressure resulting in flammable loss of containment within an underground valve pit.

CER staff evaluated the following elements:
CER staff observed a difference in focus between the field and the EOC regarding safety practices, with the field responders focused more on the hazard assessment at the site for deployed apparatus and the EOC responders focused more on the simulated emergency and hazards posed by the vapour release. The response organization chart in the PERT manual and in the situation status display board in the EOC each have a position for a safety officer, but during the exercise CER IOs did not observe a company assignment to this position. Given the timeframe of the exercise (90 minutes) there may have been an over-reliance on the Fire Department, the company’s personal air monitors, and the SAFER dispersion modelling to protect responders and the public. That said, CER IOs observed excellent coordination and communication among the responders throughout the exercise.

CER staff heard during the debrief that the pace of the response was quicker than normal and observed that the company had prepared the dispersion modelling and had other supports up and running before the exercise started.  To improve realism related to response times, future exercises can include bringing in technical support staff in real time to develop dispersion models on where the vapour plume would move based on environmental conditions or by developing more injects to be commensurate with the pace and complexity of a full-scale exercise. CER staff acknowledge that exercise artificialities are a common challenge and that there are some elements, such as external participation, that are outside of the company’s control. Addressing the opportunities for improvement identified during the exercise debrief will assist Genesis Pipeline Canada Ltd and Nova Chemicals in increasing their preparedness capacity which will lead to a more effective response to a pipeline emergency.

Through CER staffs’ evaluation of the elements listed above and a review of the documentation provided, CER staff noted that the company response actions were executed according to the Nova Chemicals Pipeline Emergency Response Team Emergency Procedures Manual, which applies to the Genesis Pipeline. The company’s objectives for the exercise were met.

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