Compliance Verification Activity Report: CV2021-487 - Minell Pipeline Limited

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-487
Start date: 2020-12-01
End date: 2020-12-01

Team:

Regulated company: Minell Pipeline Limited

Operating company: Minell Pipeline Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Evaluate a table top exercise in Russell, MB. The objectives include: 1. Validate training and awareness of the Minell Emergency Procedures Manual. 2. Validate the EOC can implement Incident Command. 3. Validate that users are able to use technological supports (e.g. Corporate Emergency Management Program (CEMP) Site, CEMP Mapping, EOC WebLog, MS Teams) effectively to activate the EOC. 4. Validate that users are able to use technological supports (e.g. CEMP Site, CEMP Mapping, EOC WebLog, MS Teams) effectively to gain situational awareness and share it in the EOC. The last exercise the CER attended was 27 March 2017.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Ruckus in Russell - Emergency Response Exercise Evaluation

Date & time of visit: 2020-12-01 07:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Exercise Planning and Conduct

On 1 December 2020, between 08:30-12:00 CT, Minell Pipelines Limited (Minell or the company) conducted a virtual table top exercise in Russell, MB. The scenario, developed to test the Minell Emergency Procedures Manual (EPM), involved a vehicle accident at the Russell Gate Station resulting in a gas release on a 6 inch mainline.

In attendance at the exercise were twenty-one (21) company personnel and two (2) Emergency Management Officers from the CER. 
Prior to commencing the exercise, the emergency response coordinator outlined the expectations of testing the new EPM. Tested information included confirmation that task specific information, contact information and resources listed were accurate. Instructions for individual conduct were explained. Participants were to announce who they were calling, be explicit as to where the information had been obtained (e.g.: From the EPM) and the specific steps they were taking. If participants were relying on individual knowledge that was to be identified so the EPM could be updated accordingly.

It was acknowledged that MS Teams was new for many participants and time was taken to discuss a number of the ways that the internal participants could connect via teams and participate in the various pre-established video conferencing rooms as required.
In advance of the exercise, on 24 November 2020, Canada Energy Regulator (CER) staff received exercise evaluation criteria, overarching objectives and agency specific objectives. On the day of the exercise CER staff received the planned injects to be used throughout the exercise.

Exercise Objectives

Minell identified the following exercise objectives:

1. Validate training and awareness of the Minell Emergency Procedures Manual.
2. Validate the Emergency Operations Centre (EOC) can implement Incident Command.
3. Validate that users are able to use technological supports (e.g. Corporate Emergency Management Program (CEMP) Site, CEMP Mapping, EOC WebLog, MS Teams) effectively to activate the EOC.
4. Validate that users are able to use technological supports (e.g. CEMP Site, CEMP Mapping, EOC WebLog, MS Teams) effectively to gain situational awareness and share it in the EOC.
 
While areas to create efficiencies and foster additional awareness and understanding were identified it was noted that the exercise objectives were met. Areas to create efficiencies were addressed in the After Action Report (AAR) that was provided to the CER on 16 December 2020.

Exercise in Play

The exercise commenced at 08:45 CT. It was reported that an accident had occurred at the Russell Gate Station and a roaring gas sound was heard. Personnel were dispatched to the scene and initial assessment and notifications began. Fire and police established roadblocks to control the perimeter. Additional company personnel were dispatched to Binscarth to isolate the pipeline by shutting the required valves.
The Site Incident Commander contacted the EOC Director as part of the notification procedure. The EOC Director established incident details, the need for additional resources and discussed secondary hazards, including injuries, fire and explosion. It was confirmed there was no one remaining in the vehicle. Due to safety concerns site access was limited until the gas pressure had been controlled.
 
Notification and Reporting

Initial field notifications were discussed and completed. At 08:55 CT, the EOC Director determined the release a level two (2) emergency and initiated the internally required notifications up the chain of command. External notifications were identified and included the Transportation Safety Board (TSB), CER and Rural Municipalities of Russell and Binscarth.

CER staff noted that the EPM does not reflect the one window reporting between the TSB and CER. CER staff prompted participants to wait for the CER to call after the TSB notifications were complete. Including this information in the EPM would facilitate more efficient and proper notification protocol.

CER staff noted that the information exchanges between the Company and the TSB and CER were rushed. The information exchange would have benefited from slowing down the flow of information and waiting for prompts from the regulators as they have a list of predetermined information they require.

The EOC Director completed the CER Online Event Reporting System (OERS). CER Staff noted that the EOC Director would benefit in delegating external notifications to the Liaison Officer. This would allow the EOC Director to complete more pressing incident response measures.

Response Management

The EOC was activated virtually through the Manitoba Power and CEMP sites. A pre-populated MS Teams account was used for the EOC in tangent with the online CEMP system. CER staff noted that responders were competent in using the online EOC software and were able to see the situation board being updated and the various incident command system (ICS) roles being filled.

EOC roles were identified and filled. These roles included Operations Lead, Planning Lead, Administration Lead, Logistics Lead, Information Officer, Liaison Officer and a Risk Management Officer. CER staff noted that individuals were tasked with multiple roles. “Getting Big Quick” and committing more individuals to the response rather than assigning multiple roles to one individual would assist in ensuring response objectives were met.

The company quickly identified the need for various equipment and discussed multiple options for how to successfully isolate the line and minimize the impact of service disruptions. These discussions included:

 
The exercise concluded at 10:37 CT. All staff were directed to complete tasks and close any reporting loops prior to the debrief commencing.  

Post Exercise Debrief

During the debrief learnings and improvements were identified, discussed and documented. Overall, Minell staff felt that the objectives had been met and that internal and external communication was effective. In particular it was noted that the three way communication used by EOC Director was very effective.

Some participants felt that the tabletop could have been expanded to also include a virtual field component. The Emergency Response Coordinator committed to including field crews in the next exercise. Company staff identified that the following areas for improvement:Things that worked well:

Compliance tool used: No compliance tool used

Observation 2 - CER Observations

Discipline: Emergency Management

Categories:

Facility:

Observations:

CER Staff Observed that:

The emergency procedures manual does not reflect the one window reporting between the TSB and CER. Including this information in the EPM would facilitate more efficient and proper notification protocol.

The information exchanges between the Company and the TSB and CER were rushed. The information exchange would have benefitted from slowing down the flow of information and waiting for prompts from the regulators as they have a list of predetermined information they require.

The EOC Director would have benefitted in delegating external notifications to the Liaison Officer. This delegation would allow the EOC Director to complete more pressing incident response measures.


 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Minell Pipelines Limited is requested to file an updated after action report (AAR) that includes consideration of the CER’s observations.  

Follow instructions in the Documents section to upload and submit the AAR by the date specified. 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: 2021-01-29

Date closed: 2021-01-18
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