Compliance Verification Activity Report: CV2223-220 - Milk River Pipeline Ltd.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-220

Start date: 2022-09-29

End date: 2022-09-30

Team:

Inspector 1618

Regulated company: Milk River Pipeline Ltd.

Operating company: Inter Pipeline Ltd

Province(s) / Territory(s):

Alberta

Discipline(s):

Emergency Management

Rationale and scope:

On 29 September 2022, a Canada Energy Regulator (CER) Emergency Response Exercise Evaluation Team (evaluation team) attended the Milk River Pipeline Boom deployment drill in Medicine Hat, AB. The evaluation team included 1 CER Inspection Officer, 1 Emergency Management Specialist, and 1 CER observer. The Milk River Pipeline is operated by Inter Pipeline Ltd. (Inter Pipeline). As a member in good standing of Western Canadian Spill Services (WCSS), Inter Pipeline would potentially utilize WCSS resources in the event of a spill on the Milk River Pipeline. The equipment deployment drill was a regularly scheduled WCSS large river deployment training program. WCSS Staff conducted the training and numerous different companies participated in the training. Members of the Medicine Hat Fire Department also participated. The training included both dryland and on-river training. Inter Pipeline had field, technical, and regulatory staff in attendance. Inter Pipeline noted that its participating staff were individuals who operate the Milk River Pipeline and other Inter Pipeline systems within the WCSS Area 2 where the exercise occurred.  Exercise participants were required to complete WCSS online training prior to participation in the exercise. Inter Pipeline stated that the objectives of the exercise were as follows:   <ul> <li>OUTCOME GOAL <ul style="list-style-type:circle"> <li>The goal of Co-op exercises in large rivers is to enable attendees to support their Operations Section Chief or designate with the development of equipment to contain and recover the spilled material where boats and specialized equipment are required and/or to protect sensitive areas. </li> </ul> </li> </ul>   <ul> <li>LEARNING OBJECTIVES - At the end of the exercise’s attendees will be able to: <ul style="list-style-type:circle"> <li>Function within a basic ICS structure. </li> <li>Describe WCSS’ role in a spill response. </li> <li>Conduct a hazard assessment for a spill response site. </li> <li>List spill reporting requirements. </li> <li>Identify the WCSS Oil Spill Contingency Manual. </li> <li>Describe the types, locations, and process to obtain WCSS spill response equipment. </li> <li>Prepare the staging area and equipment for containment and recovery activities prior to a Subject Matter Expert and certified boat operators’ arrival on site. </li> <li>Participate in a basic equipment deployment on a large river. </li> <li>Prepare for basic wildlife response. </li> <li>Provide exercise evaluation feedback.</li> </ul> </li> </ul>

Compliance tool(s) used:

None

Facility details

Facilities:

MILK RIVER
Milk River Pipeline

Facility Types

Pipeline

Pipeline

Regulatory requirements

Regulatory requirements that apply to this activity:

Canadian Energy Regulator Act (CERA)

Canadian Energy Regulator Act (CERA)
Onshore Pipeline Regulations (OPR) 2020-03-16

Plans And Procedures

Emergency Response Plan (ERP)

Milk River Pipeline ERP

Spill Response Plan (SRP)

Western Canadian Spill Services Emergency Response Plan

Observations (no outstanding follow-up required)

Observation 1 - Milk River Pipeline Emergency Response Exercise Evaluation

Date & time of visit: 2022-09-29 08:00

Discipline: Emergency Management

Categories:

Exercise Planning and Conduct

Scenario Briefing
Site-specific Hazards
General Safety Briefing
Scope of Exercise
Participant Package
Exercise Objectives

Communications

Organization of Stakeholders
Coordination with Responders

Safety

Personal Protective Equipment
Monitoring/Safety Equipment

Post Exercise

Debrief Meeting
Participant/Stakeholder Feedback
Evaluation Against Objectives

Response Management

Roles and Responsibilities
Response Priorities/Incident Objectives
Mobilization of Resources/Equipment
Maps and Modeling

Response Tactics

Site Layout
Plans and Procedures
Site Security/Access Management
Control Points
Hazard Monitoring
Deployment of Containment Equipment
Protection of Environmental Receptors
Protection of People

Emergency Response Manual

Emergency Response Procedures
Roles and Responsibilities
Emergency Response Equipment and Supplies
Public Safety Measures

Facility:

Observations:

The scenario for the exercise was an oil spill into the South Saskatchewan River upstream from Medicine Hat, AB. A pre-identified control point at Echo Dale Regional Park is included in WCSS emergency response plans and this was chosen as the location for the exercise. Companies that utilize WCSS services may use WCSS emergency response plans in conjunction with their own company-specific plans.

CER staff evaluated aspects of the following elements:

Exercise Planning and Conduct
Safety
Response management
Communications
Response Tactics
Post Exercise
Emergency Response Manual

CER Staff note that its assessment of the above-noted elements considered the limited and focused scope of the exercise; that is, an equipment deployment drill as compared to a full-scale exercise.

No non-compliances were identified during this exercise and CER Staff are of the view that the exercise objectives, as listed above, were met. Considering the limited scope of the exercise, CER Staff are of the view that the skills gained through the equipment deployment will contribute to the efficacy of Inter Pipeline's broader emergency management program, particularly in areas related to response planning and tactical response, safety, and interoperability with response agencies and organizations.

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

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