Compliance Verification Activity Report: CV1920-061 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV1920-061
Start date: 2019-09-18
End date: 2019-09-18

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

As part of the NEB's annual compliance planning, Enbridge was identified to verify the company's response capabilities during an emergency response exercise on Line 3. Although the company has indicated that the initiating event for this exercise is not based on an incident from Line 3, the exercise should evolve using the emergency response procedures that Enbridge has identified in its Prairie Region Integrated Contingency Plan. The Prairie Region Integrated Response Plan applies to all Enbridge assets that are regulated by the CER in Alberta.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Exercise Planning and Conduct

Date & time of visit: 2019-09-18 16:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Inspection Officers of the Canada Energy Regulator (CER) attended a table top exercise hosted by Enbridge Pipelines Inc. in Regina, SK on September 18, 2019.  The exercise was held to meet the company’s requirement to demonstrate compliance to s.32-35 of the CER's Onshore Pipeline Regulations. A Situation Manual and Exercise Plan were available and shared with the CER before the exercise. 

The exercise facilitator reviewed the scope and objectives of the exercise with the participants prior to commencing the discussion. The objectives that the company established for the exercise were realistic and attainable. A safety moment and egress and muster procedures were also covered.

Evaluation of the exercise was discussed, and the exercise facilitator noted that the CER officers as well as a company representative were present and that they would be evaluating the exercise.  It was stressed that evaluation was targeted at procedures and not at an individual’s performance or knowledge in the discussion.  The facilitator identified that there were varying levels of EM expertise among the staff present at this exercise as some were there to gain additional knowledge and some experience in issues that arise during an emergency response.

The initiating event for the exercise was a 911 call from a resident who could smell oil near his home.  This is possible as Line 4, for instance, runs through a residential area.  The exercise was discussion-based, with participants assigned to one of six groups who went through a series of questions based on the evolution of the scenario at a point in time (T+1 minute, T+26 minutes and T+2h41min). Each group had a measured amount of time to discuss the questions and then elected a speaker to present to the plenary.   Speakers were to be rotated to encourage participation by all attendees. The exercise facilitator would then present the next evolution of the incident. 

There was one municipal representative and two to four company representatives from different areas of the company at each table.  CER inspectors suggested that an increased group size at the tables could have enabled multiple emergency services representatives (e.g. fire and police instead of fire or police) to participate which would have provided additional value to the discussions.  

CER inspectors observed that company staff and agency representatives were engaged with each other and respectfully sharing information on each group’s response processes and expectations.  This style of exercise enables more relationship building between first responders and company staff as there is more time available for discussion at a table top than at a functional exercise. It was observed to have increased the participants’ knowledge of what reasonable expectations would be in the event of an incident.  

 

Compliance tool used: No compliance tool used

Observation 2 - Notification and Reporting

Date & time of visit: 2019-09-18 16:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Notification and reporting were discussed and the CER observed that the key agencies and internal company notifications were addressed. However, at some tables it was observed that the timing of when notifications would be conducted was not realistic e.g. not all agencies will be notified within the first minute of an incident.  CER inspectors consider this to be an artificiality induced by the exercise design as groups were given ample time to discuss the questions.
 

Compliance tool used: No compliance tool used

Observation 3 - Safety

Date & time of visit: 2019-09-18 16:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Safety was a central theme at all stages of the exercise and was clearly a priority for all participants.  As the exercise was focused on an urban setting, downtown Regina, participants were very aware of the specific public safety requirements and explored intial and longer-term considerations together.

Safety plans, field level hazard assessments, personal protective equipment, vapor monitoring and decontamination were all addressed.

Compliance tool used: No compliance tool used

Observation 4 - Response Management

Date & time of visit: 2019-09-18 16:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Reference documentation, including the Prairie Region Integrated Contingency Plan, the Field Emergency Response Guide and Inland Tactics Guide were available to each group. While the company made good use of the tools available to them, the field response guide was the most consulted, which was appropriate for this stage of the simulated incident.

The company identified that it uses the Incident Command System and was familiar with the roles, positions and forms to be used during the various stages of the exercise. There was good application of the system, including how the company addressed the transition from daily roles and responsibilities to the formal roles and responsibilities assigned to staff in the escalation of their response to the incident. The company quickly identified the need to bring in additional resources (people and equipment) in anticipation of assigning more staff to roles in their Incident Management Team. They explained that their ICS org chart could expand more quickly in this area due to the availability of staff at the Regina office who could be assigned to the incident.

The company staff identified locations of equipment caches and personnel and quickly assessed that the incident would need additional resources. These staff determined that, within the first half hour of the incident, they would call on the Gretna, Cromer and Estevan operational areas for additional people and equipment.

An aerial picture of the residential area near the simulated pipeline incident was provided.  There were no additional visual aids or maps depicting utilities which could have aided some of the discussion in Module 3 (Incident Command) of the TTX.

Although not established, due to this being a TTX, set up of staging areas and equipment and personnel check-in requirements were discussed during Module 3.

Compliance tool used: No compliance tool used

Observation 5 - Communications

Date & time of visit: 2019-09-18 16:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

This exercise provided a useful opportunity for the company to engage with emergency services personnel.  CER Officers observed each group learning about the other’s expectations.  An important point was the definition of short-term and long-term impacts and how that varies based on the perspective of the agency, e.g. a short-term response for first responders in measured in minutes and hours where a short-term response for the company can go days to weeks.  This variance could be due to the inclusion of the site remediation activities that the company would have to undertake after the gross contamination has been removed.

In addition, there was some discussion at all tables regarding the formation of a Unified Command (UC) in response to this simulated incident as well as who the jurisdictional authority would be.  In some places it was said that although there would be UC, the company would be the main IC in charge.  It is the expectation that Enbridge, as the operator of the pipeline, would have responsibility for cleaning up the spill and mitigating other effects. An Authority Having Jurisdiction (AHJ), in this scenario, must have some statutory authority for a pipeline emergency.  The City of Regina has jurisdiction on public safety for its citizens, and the Canada Energy Regulator is the AHJ on pipeline operation (which includes accidents and malfunctions) of the Enbridge pipeline.  The first AHJ on scene would be Regina Fire & Protective Services.

Compliance tool used: No compliance tool used

Observation 6 - Response Tactics

Date & time of visit: 2019-09-18 16:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Impacts on local residents were considered, particularly in regards to notification requirements, evacuation needs, exclusion fencing and ongoing means of communication.

Other site response activities that were discussed included the establishment of road blocks, prevention of migration of the oil into sewers, identification of potential high consequence areas and environmentally sensitive areas, potential for oiling of local wildlife (birds), collection of pooled product, vapour monitoring and decontamination.  Public and Responder safety was central to these discussions.

Control Point Maps (CPMs) have been created by the company, but there was no special tactical deployment specific to this site, as most CPMs identify strategies at water crossings. Company staff did explain the sensitivity mapping they undertake to create these maps and how they have grown over time to include cultural and heritage resource protection. 

Compliance tool used: No compliance tool used

Observation 7 - Post Exercise

Date & time of visit: 2019-09-18 16:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

An exercise debrief was held with all participants in the room: the exercise facilitator gave each person an opportunity to share their thoughts with the group.  The facilitator also requested that written comments be submitted on the forms that were provided.  The CER observed that at least 50% of the participants submitted written comments.

Many participants highlighted that they felt that this style of exercise was a positive experience for them as it gave additional time for discussion of roles, responsibilities and procedures at various stages of the response.  Both groups (emergency services personnel and company staff) reported an increased appreciation of the protocols, capabilities, expectations and perspectives of the other group. 

CER officers are of the opinion that Enbridge appropriately implemented its emergency response plans and demonstrated its ability to respond to the scenario exercised in this activity.

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