Compliance Verification Activity Report: CV1920-120 - Montreal Pipe Line Limited

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV1920-120
Start date: 2019-12-10
End date: 2019-12-11

Team:

Regulated company: Montreal Pipe Line Limited

Operating company: Montreal Pipe Line Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

As part of the Canada Energy Regulator's annual compliance plan, MPLL has been targeted to verify, during its tabletop exercise, its capacities for response with its public and private partners operating in Quebec.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Introduction

Date & time of visit: 2019-12-12 14:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Introduction
On December 10 and 11, 2019, MPLL organized a large-scale tabletop exercise in Cowansville, Quebec. The scenario involved in this exercise was an oil spill that occurred after an external incident and damaged the transmission pipeline that crosses this municipality.
This exercise brought together about 80 people (intervenors, observers, exercise organizers) from private (the company and its intervention partners) and public organizations (the Town of Cowansville; the Organisation de la sécurité civile du Québec, the Sûreté du Québec, and Urgence-Environnement for the provincial government, and the Royal Canadian Mounted Police and the Canada Energy Regulator for the federal government). Given that many intervenors spoke French only, English only, or were bilingual, bilingualism efforts were made throughout the exercise: bilingual facilitation, presentation media in both official languages, and ad-hoc translations by bilingual people.
The exercise was held over a day and a half. The first day was devoted to presentations on the roles and responsibilities of the various private and public organizations that must respond to a pipeline oil spill, while the second day was the actual exercise. The scenario officially began on December 11 at 8 a.m. and ended at around 2:15 p.m. before giving way to a debriefing period to ensure that everyone's practices were improved inside each organization and for their coordination between each other. Specifically, the exercise involved responding to an oil leak from its transmission pipeline. The leak was detected in Cowansville by the company's control centre and confirmed by its emergency responders on site.
This exercise was assessed by an emergency management inspector from the Canada Energy Regulator (CER), supported by a colleague who is a mobilization expert. The objectives consisted in, on the one hand, assessing the effectiveness of the company's emergency management depending on the incident and the specific response conditions (locations, partners, equipment, weather, etc.) and, on the other hand, in assessing the company's coordination with all the partners involved for the benefit of public and intervenor safety and of environmental and property protection.

 

Compliance tool used: No compliance tool used

Observation 2 - Exercise assessment

Date & time of visit: 2019-12-12 15:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Alert
According to the scenario, the company's internal and external alert system was considered to have been completed when the exercise began. The procedures for alerting company intervenors and external organizations were submitted as completed in the initial exercise instructions. These bodies include the regulatory agencies to be contacted as soon as possible by the company: the Ministère de l'Environnement du Québec, the Transportation Safety Board, Environment Canada, and the Canada Energy Regulator.

Health and safety
As stated at the beginning of the written scenario and repeated orally at the start of the exercise, intervenor and citizen health and safety is considered the company's number-one objective. In this context, the company was able to prove, in conjunction with its public and private partners, that it was ensuring proper standards for safe emergency operations. A company health and safety officer, dedicated to health and safety within their incident management team, completed a health and safety plan for the emergency operations for this incident while monitoring possible injuries or other complications and responding to them, if necessary. The officer's responsibilities included monitoring air quality and environmental hazards, personal protective equipment, first aid, and accident prevention.

Environment
Environmental protection, and especially sensitive area protection, was defined by the company and the scenario, in conjunction with the partners concerned, as one of the three main objectives of their emergency operations. CER officers observed quick and effective collaboration between the company and the public organization responsible for the environment and in attendance at this exercise (the Ministère de l’Environnement du Québec), and with private partners responsible for collecting and cleaning up oil in affected areas, as part of the Quebec emergency management coordination system.
Through discussions considered open and transparent by the various intervenors involved, collective priorities were clarified (knowledge of the product and its volume, air quality, drinking water outlets, oil collection equipment, management of polluted soils and liquids, evacuation of the population, etc.) to address the environmental pollution issues simulated by this exercise.

Emergency management and tactical response
As stated in the MPLL plan, the company implemented its Incident Command System (ICS), with the key components required to manage a spill such as that in the proposed exercise. The company's Incident Command Post (ICP) was set up at the Cowansville town hall, which housed the various incident management areas in addition to MPLL Incident Command: planning, operations, health and safety, finance, logistics and administration.
The town hall was also the site of the simulated municipal On-Site Emergency Operations Centre (OEOC), coordinated by the Cowansville Fire Department's designated officer, and the municipal Emergency Coordination Centre (EMCC), managed by the Cowansville Emergency Measures Coordinator (the fire chief). The OEOC brought together all representatives from field response agencies, including a representative from MPLL, on site on a permanent basis. The EMCC was composed mainly of representatives from the various municipal departments involved in the management of this incident, to which were added, at times, Quebec government organizations and the pipeline company.
Coordination between the OEOC and the ECC was primarily through their respective coordinators, and coordination between the OEOC, the ECC and the company command post was through the company representatives in these two decision-making centres. In general, the CER officers observed good cooperation among all intervenors, thanks to mutual respect for each other's roles and responsibilities and a willingness to contribute collectively to the best of their knowledge and resources. Efforts to overcome the language barrier were also observed, often informally and voluntarily on the part of those who had a sufficient command of French and English. In this context, the essential points of the operations were shared and discussed to put together a concerted and coordinated response. The exercise ended with MPLL's last tactical meeting, the goal of which was to provide an update on tactics, both current and to be considered, for adequately meeting the objectives of the current emergency response.

Communications
With regard to the previous point, operational communications among intervenors have progressed positively, despite some difficulties observed from time to time. External communications to the public (evacuation, notices, etc.) and to the media (press release, press briefing, etc.) could be conducted as operations and the incident management action plan developed based on the concerns and realities of the various public and private partners. It was noticed that the first press briefing came in late.

Recommendations
In light of the above observations on the exercise planned and conducted by MPLL, the CER officers recommend the following:
- For exercises of a scale approximately equal to or larger than this one: Keep them at two days, the first of which allows for a better mutual knowledge of the various participants involved. This is a good practice that significantly improves the exercise while, in the longer term, promoting the effective cooperation of all in the event of an actual incident.
- When the exercise does not involve a field deployment in addition to the establishment of coordination centres, use the term "tabletop exercise" rather than "full-scale exercise," which applies only to those that are fully deployed, including in the field.
- Plan a scenario that realistically stimulates the OEOC throughout the exercise, while avoiding a cessation of its activity as observed in this exercise.
- Continue efforts to make MPLL staff more bilingual and, during exercises at the planning stage and of a scale equal to or larger than this one, do the same for translators, additional bilingual staff, or both. This will prevent the loss of efficiency due to group discussions that are poorly conducted because of language barriers.
- Provide for a faster, more lasting MPLL presence around the ECC table, in particular with the objective of improving coordination between the Company Incident Command Post (ICP) and the ECC.
- Improve the quality of the available maps and the frequency of updates of all types of information to the MPLL ICP (status updates).
- Although coordination between ECRC-SIMEC and MPLL has been effective in mobilization and response, a specific contract should be considered to specify response costs.
- Plan to use the finance and logistics committee on-site to improve communication and cross-fertilization through the presence of its representatives at the exercise site with the other intervenors.
- Have a list of intervenors' telephone numbers available during the exercise.
- As discussed with the MPLL emergency measures representative when he started in his position, organize a large-scale exercise by the end of fiscal year 2020–2021, including a field exercise with all private, municipal, provincial and federal partners involved, as well as the inter-agency coordination centres concerned (OEOC, ECC, ORSC, FCG), while considering Ministère de la Sécurité publique du Québec emergency management as the preferred entry point for its concerted planning. For this type of major exercise, the scenario, which is always as realistic as possible, could be stimulating enough to involve a large number of public and private intervenors and keep their mobilization of interest throughout the exercise.
- Still in relation to the Ministère de la Sécurité publique du Québec:, use «Diapason »as the name for a full-scale exercise involving all jurisdictions to reinforce this good practice and to benefit from the progress made by the various intervenors with regard to Quebec's Cadre de référence Intervention Pipeline (CRIP) [pipeline response reference framework].
- Continue to systematically incorporate lessons learned from exercises and actual events into the MPLL emergency response plan. In this way, the company's review of this plan, based on the lessons learned from this exercise and from the major full-scale exercise in fiscal year 2020–2021 will undergo a compliance verification by the CER during fiscal year 2021–2022.  

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