Compliance Verification Activity Report: CV1920-241 - Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV1920-241
Start date: 2020-03-04
End date: 2020-03-05

Team:

Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Operating company: Westcoast Energy Inc. carrying on business as Spectra Energy Transmission

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

To verify response capabilities during an emergency response exercise.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Introductory Comments

Date & time of visit: 2020-03-02 09:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

The purpose of the Emergency Management (EM) Inspection is to assess the implementation and the effectiveness of Enbridge's (formerly West Coast) liaison and continuing education activities as required under sections 33 – 35 of the Onshore Pipeline Regulations.  The CER’s expectations are outlined in the Guidance Notes for the Onshore Pipeline Regulations (OPR) (https://www.neb-one.gc.ca/bts/ctrg/gnnb/nshrppln/gdncntnshrpplnrgltn-eng.html).
 
CER Staff met with Enbridge's EM staff, and staff from both the Prince George and 100 Mile House fire departments, who are both located along the pipeline route. These communities were chosen in part due to their location along the pipeline, making them communities who could potentially be directly impacted by an incident. The information below summarizes the results of this compliance verification activity.

All discussions were held over the phone and additional information was also received via email follow ups.

Compliance tool used: No compliance tool used

Observation 2 - Liaison

Date & time of visit: 2020-03-02 09:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

The CER discussed with Enbridge their efforts at liaison work they are required to carry out under the Onshore Pipeline regulations (OPR).

Enbridge is in a transition time, as they have recently taken over the operation and ownership of this pipeline from Westcoast. As such, the two programs are being merged into one, and so they are still fine tuning some aspects of the new combined program.

Enbridge responded to the CER request with information regarding those efforts and how Enbridge uses both their Public Awareness Program, (PAP) and engagement efforts with agencies who may represent those communities (fire departments and police, bc wildfire etc). Public Awareness Specialists meet triennially with local communities in a face to face setting.These face to face meetings are held with landowners, first nations and agencies who reside adjacent to the pipeline.

Enbridge prioritizes their liaison efforts, focusing first on 'Tier 1' organizations, which are those agencies that have "pipeline or associated Emergency Planning Zone through their response zone". This should allow for a concentrated effort to be focused on the agencies that would provide first response efforts, and those most directly impacted by an incident. The Public Awareness Specialists also conduct work with landowners, first nations and communities adjacent to the pipeline.

Enbridge's efforts seem to be effective, as first responders reported being satisfied with the level of interaction and information they receive from the company. Both municipalities had first hand stories of the company setting up information booths for the public to access when the company was working in their community, and had up to date Emergency Response Plans on hand. They were also familiar with who the correct point of contact was for them within the company and understood their potential role in an incident affecting their area, as well as the company's responsibilities. Both expressed interest at attending a local exercise or hosting an exercise for an even greater understanding of Enbridge's processes in an incident, and to increase their interoperability with the company.

Compliance tool used: No compliance tool used

Observation 3 - Continuing Education

Date & time of visit: 2020-03-03 09:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Enbridge's full response to the CER's questions regarding their continuing education program is located in the attachments section. The CER explained to Enbridge the reason for this inspection and outlined the requirements of the OPR sections 33-35, which Enbridge was familiar with. The Enbridge Emergency and Security Analyst displayed a strong working knowledge of the OPR requirements and was able to discuss the efforts that had been underway previous to the Westcoast - Enbridge transition, and was familiar with the plan going forward with Enrbidge's processes for continuing education. The response we received then is based both on previous efforts carried out by Westcoast, and the future plans, which will be conducted via Enbridge's ERP.

Part of the Enbridge continuing education program is a web portal they offer at www.mypipelinetraining.com which is provided for free to potential first responders. It also allows Enbridge to track who has accessed that online information in order to ensure their potential responders are up to date on Enbridge's latest Information.

Enbridge also reported carrying out regional stake holder specific education programs. To accomplish this, Enbridge's different business units will determine what outreach may be most needed in a given area, as determined by looking at an area's history of:
• potential hazards;
• areas identified as high consequence, environmentally sensitive or difficult to evacuate;
• population density along rights-of-way or near facilities;
• history of and/or potential for third-party damage;
• environmental considerations;
• history of pipeline release or safety issues in an area.

Note this is only a partial list of the considerations provided.  Please see the Attachments section for the full list, as found on page 9 of the PDF.

Once again the efforts above seem to be effective as the first responders reported being satisfied with the ongoing Information sharing they are receiving. Both mentioned feeling very knowledgeable in their role in an incident and understood the greater public safety role they would play outside of immediate pipeline response (evacuation, wetting vegetation, site security etc).

Compliance tool used: No compliance tool used

Observation 4 - Interoperability with responding agencies

Date & time of visit: 2020-03-04 09:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Enbridge uses the ICS system for responding to incidents on their pipelines, which is also used by the agencies interviewed for this inspection. Further, the agencies interviewed showed a high familiarity with the company's  processes and personnel who would be responding alongside them. Through the triennial face to face meetings and the public awareness program, both response agencies and the public have input into the emergency response plan (ERP) Enbridge creates. This allows for not only interoperability but also for local knowledge and concerns to directly shape the ERP.

Both agencies stated they would like the opportunity to host or attend an exercise held by the company. In discussion with the company, their EM Analyst supported the idea of hosting something in the future. There have been internal exercises that were hosted in Prince George but municipal agencies were not in attendance. Enbridge also is pursuing an exercise that may involve the Prince George Industrial Mutual Aid Group, which would then expand the audience to other industrial groups as well. there is not timelines for this yet, as the city and mutual aid group would also need to schedule time for this. Prince George had separately discussed with the CER the PGIMAG option for hosting and being involved in exercises, showing that both parties recognize the benefit of a wide audience for information sharing. Both municipal agencies did mention that they can be overwhelmed with requests to attend all sorts of exercises, events and fundraisers, so early planning was discussed as being a key item for their ability to attend.

Neither responding agency voiced any serious concerns about interoperability. They both recognized that there is always room and desire for greater interaction, but stated they were satisfied with the efforts Enbridge (and formerly Westcoast) has made, and their level of information and knowledge of concerns, threats and response considerations around this pipeline.

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