Compliance Verification Activity Report: CV2122-022 - Enbridge Pipelines Inc.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-022
Start date: 2021-08-11
End date: 2021-08-20


Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):


Rationale and scope:

Verify response capabilities during a table top exercise held on 11 August 2021 on Line 21 in Tulita, NT.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Tulita Table Top Exercise - Emergency Response Exercise Evaluation

Date & time of visit: 2021-08-11 09:00

Discipline: Emergency Management




On August 11th, 2021, a Canada Energy Regulator (CER) exercise evaluation team consisting of three CER staff attended a virtual table top conducted by Enbridge Pipelines Inc. (Enbridge). Personnel in attendance included company staff and first responders from Edmonton and Calgary, AB as well as Tulita, NWT. The scenario was developed to facilitate discussion on the emergency response actions and capabilities of Enbridge and the Tulita Fire Department, regarding a potential discharge of crude oil from Line 21 in the Tulita area. The intent of the exercise was for responders to utilize the company’s emergency response plan to discuss response coordination using the Incident Command System (ICS) to identify all required responding agencies and resources and discuss the establishment of Unified Command.

Following introductions and a pre-exercise briefing, Enbridge exercise facilitators moved the participants through two modules of exercise play. Each module contained a chronology of events followed by a predetermined list of questions intended to prompt discussion of multiple aspects of the response. CER staff observed that the questions asked in each module were linked to the exercise objectives established by the company.

The exercise goals and objectives were:

As the facilitator led the group through each module, they prompted the Incident Commander, Command Staff and General Staff to discuss how they would respond. The predetermined questions created a good opportunity for cross training and learnings at all levels of involvement. This group work provided a means for participants to practice implementation of ICS and to gain more knowledge of emergency response in the Tulita area.
Module 1 of the exercise focused on initial notifications and response measures including activation of ICS positions, agency and department involvement, public and environmental protection measures, and deployment of required resources. There was considerable attention placed on required notifications, communications, and stakeholder interactions. Enbridge, the Tulita Fire Department and the CER all had opportunities to describe their notification and continued communication expectations as well as their internal processes for initial response and mobilization. Enbridge accurately described the process of the emergency one call through the Transportation Safety Board and the requirement to report the incident through the CER’s Online Event Reporting System as well as to the NWT Spill Report Line. The CER staff noted that quality and accurate information was shared between Enbridge and the Tulita Fire Department during this module. The Fire Chief described the department’s capabilities, equipment, how they respond under the Hamlet of Tulita local government (including reporting to the local Municipal Emergency Operations Centre (EOC)), and their expectations of the company. CER staff noted that relevant points were discussed during this module that resulted in Enbridge achieving many of its exercise objectives.
In addition to the above protocol discussions, Enbridge indicated that they can effectively notify all impacted, potentially impacted or interested communities in the area utilizing an internal directory containing local Indigenous and non-indigenous contact information along the pipeline. This internal directory details all affected groups located on, or adjacent to the pipeline and is updated continuously throughout the year by the Enbridge Public Affairs and Community Stakeholders Team.
After Enbridge and CER participants described their external communication processes, the CER staff emphasized the need for organizations to coordinate during an emergency and develop joint messaging to ensure consistency and accuracy for community updates and media releases. Enbridge staff stated that in a real event they would seek to establish a Joint Information Centre to accomplish this coordination. During the communications discussion, it was recommended by the Tulita Fire Chief that media releases and other information be translated to Slavey, the local indigenous language.
Enbridge stated that it’s tactic was to ‘get big fast’ following confirmation of a release. The Enbridge Incident Commander was able to alert personnel throughout the organization and activate and assign work to subject matter experts. The ‘get big fast’ tactic was also applied to activation of response equipment. Enbridge discussed its response resources cached in Tulita and at Norman Wells which could be deployed for initial response. Enbridge referred to their Integrated Contingency Plan which lists equipment that Enbridge owns or has access to through mutual aid agreements, which company responders can mobilize to quickly aid initial response efforts. The logistics of mobilizing resources in the arctic environment was discussed by Enbridge on-site representatives who noted helicopters would be required to deploy equipment in the area. The isolated nature of the area would present time delays and have impacts to the response times.
Module 2 of the exercise focused on mobilization and sustainable response and included discussions around Unified Command, information dissemination, long term response efforts and potential impacts to the local community infrastructure.
Throughout the exercise, CER staff noted two underlying items of importance highlighted by all internal and external participants. One, the potential impact to the hamlet of Tulita due to an influx of response personnel and two, the priority to ensure responder and public safety as well as to minimizing environmental impacts. Minimizing the overall impact to the local population throughout the response is paramount to a remote community like Tulita which has limited lodging for external responders.  A large influx of people could potentially deplete resources depended on by the local population. Enbridge discussed creating temporary work camps as well as providing additional supplies such as fuel and groceries to the community to help lessen the local impact. It was identified by CER staff that there are many permits that are required to set up temporary work camps. The CER staff suggested that Enbridge investigate what permits are required so they can gain an understanding as to what is involved to activate a temporary work camp for response purposes. These pre-identified processes should be included in the Emergency Response Plan once the information is obtained.  
Additionally, as there is no road access (except during the winter season) to Tulita, movement of response equipment and personnel from Tulita and other areas would occur by boat or would require helicopters and longlining operations. It was also noted that Enbridge’s vessels are located in Norman Wells, which is over 70 km from Tulita. Additional discussion during this module focused on availability of helicopters , airstrip capacity in Tulita and other oilfield services  within the hamlet.  It was identified that Tulita was not in the Enbridge Integrated Contingency Plan as a potential airline charter location. CER staff noted that the Tulita airstrip should be included in the Integrated Contingency Plan or Tulita Emergency Response Plan.
CER staff described other Government of Canada resources that could be accessed during a prolonged response. Such resources could include support from the Transport Canada Maritime Aerial Surveillance Program, Environment and Climate Change Canada’s National Environmental Emergencies Centre and the Canadian Coast Guard’s Environmental Response services. Enbridge understands that these resources could be mobilized through CER staff acting as the federal Incident Commander. For continued and sustainable responses, the use of Unified Command was discussed in detail i.e. who would be involved and how. It was identified that both Enbridge and CER responders would enter Unified Command while the Tulita Fire Chief would prefer to be integrated into the municipal EOC. A municipal representative would be integrated into Unified Command as part of command staff. Overall, it was accepted by participants that participation in Unified Command is to ensure organizational objectives are met while contributing towards common goals.

The use of emergency response documents such as the area specific Emergency Response Plan, Integrated Contingency Plan and other response guides by Enbridge participants was noted by CER staff. CER staff recognize that familiarization with emergency response documentation and virtual platforms, as seen during this table top, are essential to ensure effectiveness during an actual event.
CER staff have observed that many companies across industry have shifted from in-person to virtual meeting spaces to complete required training during the Covid-19 pandemic. A challenge to this format is that training may take longer, yet exercise duration times have not been modified. This shift, which often results in an inadequate amount of time to sufficiently run an exercise, usually impacts the debrief and participant feedback session at the end of an event. CER staff require that future online exercises are lengthened in time for delivery in a virtual meeting space to ensure detailed debriefs can occur. 
During the exercise, there was insufficient discussion of the potential product that could be released and its volume and characteristics.  For instance, there was no discussion of how much oil may have been released from the pipeline and the scenario did not provide a description of the oil on the river (colour, location, extent of spread). Oil specific descriptions would have assisted in the discussion of tactical details to implement public safety and environmental protection measures.  Other missing information that would have been of assistance would have been a detailed overview of the release location and maps or photos.  Since most of the Enbridge participants were not intimately familiar with the NWT and logistics in the Tulita area (i.e., road access only in winter, airstrip capabilities, services available (accommodation limitation, heavy equipment, etc.)) these visuals would have helped situate participants to the geographical context of the exercise scenario. 
Overall, CER staff observed that participants were engaging in positive discussion resulting in all exercise objectives being met. The discussions between all participating responders and organizations allowed for increased understandings pertaining to response capabilities and expectations. The local fire department recommended that it would be good to host a future emergency preparedness information session with local residents. The exercise almost solely focused on the ICS aspect of a response, however CER staff would liked to have seen some more discussion pertaining to the operational aspect of a response given the logistical challenges identified during discussion. The CER staff recommend that Enbridge complete another exercise in 2022 for the Tulita area which focuses primarily on the operational aspects of a response in this area.

Compliance tool used: No compliance tool used

Observation 2 - Canada Energy Regulator (CER) Observations

Discipline: Emergency Management




CER staff noted the following concerns during the exercise which should be addressed in the After Action Report (AAR):

- Media releases and other information be translated to Slavey, the local indigenous language if / when possible.
- Enbridge investigate what permits are required to activate a temporary work camp for response purposes. Pre-identified processes       
  should be included in the Emergency Response Plan once the information is obtained.  
- Tulita airstrip should be included in the Integrated Contingency Plan or Tulita Emergency Response Plan.
- Future online exercises be lengthened for delivery in a virtual meeting space.


Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Enbridge is requested to file an after action report.
Follow instructions in the Documents section to upload and submit the AAR by October 6th, 2021. The AAR should describe:

The AAR should also include improvement planning such as a corrective action plan (CAP), that identifies program improvements and the necessary corrective actions required to address them, and an improvement plan, identifying the corrective actions to be taken, the responsible party or agency, and the expected completion date.

Due date: 2021-10-13

Date closed: 2021-10-13
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

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