Compliance Verification Activity Report: CV2223-061 - Many Islands Pipe Lines (Canada) Limited


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-061
Start date: 2022-05-18
End date: 2022-05-18


Regulated company: Many Islands Pipe Lines (Canada) Limited

Operating company: Many Islands Pipe Lines (Canada) Limited

Province(s) / Territory(s):


Rationale and scope:

Ensure MIPL is prepared to respond to an emergency. Verify that response actions are based on the EPM and company procedures; assess whether the EPM and procedures protect the health and safety of the public and responders, property and the environment; determine whether exercise objectives were met; and ensure that no effects or potential effects result from participants’ actions or lack of actions. Verify that improvements have been made since the previous CER exercise evaluation under CV1819-152.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - MIPL Full Scale Exercise

Date & time of visit: 2022-05-18 08:00

Discipline: Emergency Management




MIPL Full Scale Exercise

Two Canada Energy Regulator (CER) Inspection Officers (IO) attended the Many Islands Pipeline Limited (MIPL) full scale exercise on May 18, 2022, in Regina and Macklin, Saskatchewan. MIPL’s exercise had both an Incident Command Post (ICP) component in Regina and a field response that involved mobilizing personnel and equipment to a simulated response to a  natural gas release near Macklin. The field component exercised a multi-agency response as the RCMP, and both Macklin and Unity Fire Departments played active roles. The exercise met the CSA Z246.2 definition of a full-scale exercise.

MIPL staff, participants and observers began the exercise with introductions and a land acknowledgement provided by MIPL. A safety briefing was held which informed on-site participants of locations of bathrooms, evacuation routes, the building’s muster point, and the location of automated external defibrillators in the building. Certified first aid staff were also identified.  The exercise goals and objectives, as stated below, were reviewed. The exercise scenario was that a farmer had struck the MIPL line, causing a release of sweet natural gas – there is no ignition of the released natural gas.

It was noted by CER staff and confirmed in discussion with MIPL, and stated in their emergency response plan, that MIPL uses an incident management system that is based on the Incident Command System (ICS), having  been tailored to meet MIPL’s needs. Parenthesis will be used where there is a difference of terminology between ICS and the MIPL system for clarity and greater awareness of their management system.
The objectives MIPL established for this exercise were:

Exercise Play
The exercise began at 09:07 CST when the ICP (note, MIPL uses the term Incident Command Centre or (ICC)) received a call from the field location of the simulated strike on the pipeline from a farm vehicle. MIPL field responders established an initial 1600 meter exclusion area via road blocks, which exceeds the Emergency Response Guide’s safety recommendation of 800 meters. A staging area was established 2400 meters from the incident site in a large, road-side field. MIPL was able to secure this substantial safe zone due to the low population density in the area. MIPL staff determined this event to be a level 3 emergency , which CER staff confirmed aligns with the criteria set in their Emergency Response Plan.

MIPL began staffing the required incident command positions including an Incident Commander, Planning Section Chief, Environment Unit Lead and the Command Staff – Information officer, Safety Officer, Liaison Officer. Field Operations staff were also assigned by the company’s activated On Scene Commander. Staff posted a large Organization Chart (ICS form 207) on the wall reflecting these assignments.

CER staff noted that the discussions in the ICP (ICC) appropriately focused on public and responder safety. Measures such as ongoing weather monitoring including wind direction, air monitoring including monitoring of Lower Explosive Limits (LEL’s), creating an isolation plan and confirming that the pipeline was free of liquids were implemented. The Operations Section Chief (OSC) confirmed that the fire department and RCMP had arrived on scene and that roadblocks had been established to prevent entry into the safe zone. MIPL staff also confirmed there were no injuries associated with the incident. MIPL staff, RCMP and fire department members simulated evacuations from 3 homes; they also discussed the potential for other area users that may not be accounted for as “residents” within the MIPL EPM and how they would be evacuated if discovered in the area. The MIPL staff in the ICP were noted as integrating well with other team members at different tables and collaborated effectively. The exercise area also provided break out rooms that were used as needed.  Both field and ICP (ICC) staff showed a strong familiarity of the tasks they needed to complete and were efficient with their work at doing so.

The Safety Officer in the ICP (ICC) created a thorough Safety Plan for the incident. LEL’s were monitored throughout the exercise but never exceeded safety standards. At the field site, a field safety officer was assigned and briefings were held as to site safety and health effects that were possible from this event. CER field staff noted that life safety was always appropriately prioritized. A field level risk assessment was discussed and included slips, trips and falls, animals, ticks, speed limits in the area, farm equipment hazards, lifting techniques, pinch points, gas venting on site, wind direction, ignition sources, and hazards of driving near or through plumes.

Management System
Rather than follow the ICS ‘Planning P’, MIPL’s system is to perform calls between the field and ICP (ICC) usually occurring 60 minutes apart. In these calls response-tasks would be identified for each group to complete, with updates provided on those tasks during the following call. This method proved effective for both groups and MIPL’s staff showed strong familiarity and efficiency with this method. This modification of the traditional system still follows the ‘management by objectives' methodology of ICS.

Throughout the exercise information was shared between the ICP (ICC) and field staff through these calls. Information that was shared included updates on number of MIPL staff in the field, timing of notable events such as approaching the site, roadblocks being established and updates on the results of air monitoring.

CER staff noted that all MIPL staff were recording work on ICS forms 214 (Activity Log), and that hard copies of their Emergency Procedures Manual were available as well as e-versions through the company website. Forms and notes were retained from this exercise for review and record keeping purposes. 
Communication between ICP (ICC) and field staff was accomplished through cell phones, text and Microsoft Teams. Communication methods were reliable and cell service was available in the area of field operations. The Liaison Officer in the ICP (ICC) simulated response updates to local municipalities and potentially impacted First Nations communities as well as downstream users of the pipeline. MIPL performed notifications to the CER / Transportation Safety Board (TSB) to ensure accurate contact lists.
CER IO’s in the field and at the ICP noted that communication between the locations, was effective.

Exercise Conclusion
The exercise was concluded with the field team reported that the pipeline had reached an operating pressure of zero, indicating the product had completely evacuated the pipeline. The exercise day concluded fully when the staff in the ICP (ICC), including observers from other agencies, debriefed and provided their feedback on areas that were seen as particular strengths, and areas to focus on for improvements in future exercises. 

Strengths that were noted included the continual update of real time wind and weather data, the existence of pre-identified homeowners in the impacted area, communication methods that were reliable and easy to use, and a functional layout of the ICP (ICC) which allowed for break out rooms. On review of previous exercise observations, it is noted that MIPL has made improvements in their management system work from previous exercises, which is an area they commented on focusing on in future exercises. MIPL staff maintained their roles through the exercise day and generated paperwork consistent with accepted management systems, which had been noted as a previous potential issue. MIPL also noted that standardizing their terminology with partner agencies was a benefit to ensure interoperability of their system with partner agencies.   

Areas to focus on included greater exposure to incident management system training for some participants, continue to include partner agencies in future exercises, and consideration of standardizing  communication methods as Microsoft Teams, text, cell phone and instant messaging were all being used.

CER staff noted that MIPL’s management system functioned well for them and that their team worked well together. They also noted great external agency interest, participation and questions for the company about responses and roles.

As mentioned in the above report, CER staff noted improvements from CV1819-152, including: 
Best practices appeared to be followed and no non compliances were noted during this exercise.


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