Compliance Verification Activity Report: CV2021-456 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-456
Start date: 2020-11-02
End date: 2020-11-02

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Evaluate an exercise to verify response capabilities as per the condition. Exercise scheduled for 15 April 2020 was rescheduled to 2 November 2020 due to the COVID pandemic.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Emergency Response Table Top (Virtual)

Discipline: Emergency Management

Categories:

Facility:

Observations:

Exercise Planning and Conduct
 
An Emergency Management Exercise Evaluation Team of the Canada Energy Regulator (CER) attended the Alberta Line 93 table top exercise (TTX) hosted virtually by Enbridge Pipelines Inc. (Enbridge) on the 2 of November 2020. The team consisted of an Inspection Officer (the Officer), the Group Leader of the Emergency Management and Security Team and the Technical Leader for Emergency Management. In addition the Evaluation Team was joined by an Indigenous Monitor from the Line 3 Indigenous Advisory Monitoring Committee (IAMC). 
 
The exercise was conducted to support the company’s Emergency Management Program requirements as per s.32 of the CER Onshore Pipeline Regulations, CSA Z662-19 clause 10.5.2.4., and for compliance to Condition 35 (a) of Order OC-063 requiring that an exercise specific to this line be conducted in Alberta. An Exercise Plan and player card was available and shared with attendees and the CER before the exercise.
 
The exercise involved Enbridge personnel and management as well as additional representatives from the CER and Line 3 IAMC who were not attending as part of the CER Evaluation Team. Alberta First Nations were invited and attended. First Responders from local emergency services, several fire departments, the RCMP, the city of Edmonton and the provincial emergency management agency were in attendance. The exercise and training delivery was facilitated by a Contractor, The Response Group (TRG), on behalf of Enbridge.
 
The exercise and training delivery was facilitated by a Contractor, The Response Group (TRG), on behalf of Enbridge.  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 scope of the exercise focused on the initial phase of an emergency response following a liquids release, including initial response actions, notifications and mobilization of resources by the Incident Command Post.
 
The purpose of the exercise was to test and practice oil spill emergency response and procedures for Enbridge’s Line 93 pipeline.
 
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).  The first hour prior to the exercise commencing focused on familiarization with the virtual environment, a high-level orientation to the Incident Command System and an overview of the exercise plan with the approximately 44 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 by phone.  All other external notifications, except to the Transportation Safety Board (TSB) and CER, were simulated. 
 
Regarding notification of the CER, Enbridge staff did adhere to the single window reporting by calling the TSB to report the incident, who in turn called the CER.  Enbridge staff subsequently entered the incident in the CER’s online event reporting system (OERS).  The phone notification and the input of information into OERS are required to occur as soon as possible and no later than three hours of the incident being discovered. The goal of the initial phone notification is to allow the relevant agencies to mobilize a response to an incident, if required. CER staff note that Enbridge staff had confirmed the release but waited approximately 90 minutes for an estimated release volume before initiating regulatory reporting.  Enbridge should have reported the rupture by phone to the TSB and the CER as soon as confirmed, and should not have delayed approximately 90 minutes for an estimated release volume.  Estimated release volumes can be updated in OERS at any time following submission of a Preliminary Incident Report. 
 
Internal notifications were accomplished as prescribed in the appropriate company manuals and protocols. See section below on Communications. 
 
Safety
 
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 a priority of the response.  The Safety Officer simulated dispatching an Assistant Safety Officer directly to site to support responder safety and public protection.
 
Response Management
 
ICS roles were pre-assigned to Enbridge staff who used colour coded video backgrounds with the ICS role clearly identified on the virtual software during all communications.   
 
The simulated scenario initiated with a call received from a landowner who discovered a potential release of oil near a creek.  The company’s ERP was activated, operators were dispatched to site to confirm the release, and initial response actions from the ERP were implemented by the initial Incident Commander (IC).  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 live ICP.  Various meeting with all participants were held in the general channel for all and then command staff and section or unit meetings were held.  The Officer observed several meetings and break out meetings and noted participants discussing documents, working on ICS forms, and sharing information.    
 
The manuals participants were instructed to follow were the Enbridge Integrated Contingency Plan Prairie Region, the Enbridge Field ERP Prairie Region, and the Enbridge Incident Manual Handbook. The Officer noted that staff were following their company documents and discussing the contents.  Maps and system diagrams were available and used by responders.   
 
The ICS roles established followed those identified in the Company’s ERP and Emergency Response Program. The exercise used ICS documentation to develop a 201 briefing package. 
 
It was observed by the Officer that ICS forms posted directly on the exercise software and visual tools would have added more value to the management of the response especially for the participants to see, use and collaborate on.  There was another internal software application used by Enbridge staff that the CER evaluation team did not observe during the exercise; however, products from that application or not completed virtually were requested and received by the Officer following the event (expected to be received this week).

Response Tactics

The following is a description of the response actions and tactics that were simulated during the exercise discussion.

Following notification by landowners, the IC immediately dispatched operators to the site and system shutdown procedures were commenced.  Many potential response tactics would require eyes on the situation by responders who would not have arrived during the simulated timeframe of the response.  Therefore, efforts were focused on information gathering and preparing and establishing the Incident Command structure for the later phases of the response.  

A software mapping system was used to determine the extent of the oil or the potential for oil to spread in impacted watercourses. Based on location and conditions, the Planning Section identified the applicable Control Point tactical plans and initiated trajectory modelling. Information on wildlife protection was discussed and identification of potential species at risk in the area was conducted on paper.  Spill estimates were established and control points and staging areas were identified.

A large part of the exercise was identifying required and nearby or available resources.  Participants worked to mobilize these resources and track their status. These mobilizations included requesting a flyover to gain more information. 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.

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.

 Communications

The Officer notes that Enbridge staff effectively communicated during the exercise. The sound quality and the meetings held assisted in the delivery of response actions. The Officer notes that more visuals such as posting the planning P meeting schedule would help streamline future exercises as some meeting times had to be spread by word of mouth and not all meetings starting on time due to that.  As mentioned above under “Response Management”, use of the computer application’s features to post visual materials would have been more effective.   
 
Participants worked on a draft media plan but it was not shared during the exercise with participants.  It was requested and received by the Officer following the exercise.
 
 
Post Exercise
 
Overall, CER staff are of the view the table top exercise objectives were met. The training completed was in line with a table top exercise. The participants had productive discussions and demonstrated what they would be doing as it related to the exercise scenario.
 
CER staff note that the table top exercise was realistic and representative of hazards and risks associated with the Line 93 pipeline.  The total volume provided by the facilitator for the release may be larger than in a real event but was still useful for training.  Also, Enbridge participants indicated during the debriefing that having control room staff more involved in the exercise would have increased the realism of the training.
 
Participants were engaged and there was ample discussion of all tasks and frequent reminders to use ICS forms and processes. CER staff also note that there was a potentially missed continuing education opportunity as there were many attendees in the observer section (of the virtual software) who could have been more engaged or hosted by a knowledgeable guide through the exercise. 
 
As noted under Response Tactics, the company “went big quick” in its approach to requesting resources. CER staff note that this is a generally accepted principle of effective spill response.
 
The use of labeled and colour coded screen backgrounds in the virtual environment was helpful in identifying the roles of individuals within the ICS structure. This visual measure was a good adaptation to operating in a virtual environment and provided similar awareness as colour-coded vests and other markings in a physical ICP. 
 
Enbridge staff noted that they found the training helpful and appreciated the support from TRG and the use of the Indigenous Liaison Office. 
 
In summary, CER staff made the following observations:
  • More use of online visuals could help keep responders updated and information organized.
  • Greater engagement of exercise observers could result in additional continuing education value regarding Enbridge's Emergency Management Program.
  • Involving control room staff and processes in future initial actions scenarios, may improve realism and training value.
  • Earlier notification of regulators would enable quicker response collaboration and coordination.

 
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Due to the limits of what an Inspector can observe via a virtual emergency response exercise, the following documents from the event were requested in order to confirm compliance.  Also see attached emails.:

  

Due date: 2020-11-18

Date closed: 2020-11-30
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