Type d’activité de conformité : Inspection sur le terrain
Équipe :
Société réglementée : Trans-Northern Pipelines Inc.
Exploitant : Trans-Northern Pipelines Inc.
Province(s) / Territoire(s) :
Discipline(s) :
Justification et portée :
Verify company's liaison activities and continuing education program with municipal agencies in Ontario.
Outil(s) de conformité employé(s) :
Installations :
Type d’installations
Étapes du cycle de vie
Exigences réglementaires s’appliquant à cette activité :
Observation 1 - Introductory Comments
Date et heure de la visite : 2019-02-20 13:30
Discipline : Gestion des situations d’urgence
Catégories :
Installation :
Observations :
The purpose of the Inspection meetings were to assess the implementation and the effectiveness of Trans-Northern Pipeline Inc.’s liaison and continuing education activities as required under sections 33 – 35 of the National Energy Board's Onshore Pipeline Regulations (OPR). The NEB’s expectations are outlined in the Guidance Notes for the (OPR) at https://www.neb-one.gc.ca/bts/ctrg/gnnb/nshrppln/gdncntnshrpplnrgltn-eng.html.NEB Staff met with TNPI staff and staff from municipal agencies in Ontario that may be involved in an emergency response on TNPI pipelines. NEB selected two municipalities based on their size and proximity to TNPI’s pipeline infrastructure. The information in subsequent observations summarizes the results of this compliance verification activity.
Outil de conformité employé : Aucun outil de conformité employé
Observation 2 - Liaison
Date et heure de la visite : 2019-02-12 13:00
NEB Staff and TNPI discussed how the company is meeting the requirements outlined in sections 33 and 34 of the OPR. TNPI stated that their main liaison activities with municipalities are conducted via face-to-face meetings, attendance at conferences and table top exercises. Face-to-face meetings with municipal officials are scheduled once every three years and may be more frequent in those areas where spill trajectory models show impact to areas of higher population density, sensitive populations (schools, hospitals and elder care facilities) or environmentally sensitive areas. The request for the meeting is sent by the company to the Emergency Management official and they report that it is typically fire departments and emergency management officials that attend, although other municipal representatives may also be present. The company stated that it keeps minutes of the meetings it attends and selected an example to show the NEB. The list of the municipalities met over the last years was also presented to the NEB which showed how they cover Ontario every year based on a three-year cycle.During a face-to-face meeting, the company will provide information about the pipeline (regulatory information regarding pipeline operations, technical information relating to pipeline integrity and some emergency response plan information). A sample presentation for EM Outreach was shown to the NEB inspection officer by the company. The company said that feedback on the information presented is given during the meeting and that they solicit addition feedback through a post-meeting survey. The company indicated that it has used this feedback to improve its emergency response procedures. For example, during the review of the overland flow modeling in one community it was identified that a hospital had relocated to an area which happened to be outside of the pipeline’s emergency preparedness zone. The company evaluates the effectiveness of the outreach materials by the types of questions they received during face to face meetings and via post-event online surveys. TNPI maintains a Master Communications Contact List which is updated annually and, more frequently, on an opportunistic basis through information gained during liaison activities. Categories of stakeholders are also captured in their own spreadsheets eg. landowners, adjacent properties and first responders. Agencies in the Township of South Stormont told the NEB that the company had met with them in 2018 and discussed reciprocal expectations for response. It was estimated that they hear from the company, typically via email, about every 6 months. They said that the company meets with them annually to go through its Emergency Procedures Manual and to review any changes that have been made. In addition, they told NEB that TNPI delivers a municipal information session every other year. This is in contrast to Burlington where the City does not have a copy of the company’s EPM and where the representatives that NEB spoke with had not met with the company. The City’s Emergency Management Coordinator (CEMC) noted that the company had reached out to her in the fall of 2018 in order to establish an EM contact with the City. Subsequently a request was sent from the City to the Company to obtain shape files to import pipeline data as a layer into the City's GIS maps. TNPI confirmed to the NEB that the shape files were sent immediately after they were requested.The company notes that there is open access to their EPM through its public website, as per the NEB’s Order MO-006-2016.The City of Burlington demonstrated that the company delivered a general public awareness presentation to municipal representatives in 2018. A copy of the presentation shown to the City was shown to the NEB which included the following topics: an introduction to the company, its operations within Burlington, its integrity management, damage prevention and emergency preparedness programs. The last EM outreach session targeted to the City of Burlington was an emergency response exercise in 2015. The company has made contact with the CEMC for Burlington in order to schedule future sessions, which may include an emergency response exercise, with the City's Training and Haz Mat officials.Emergency Management staff in both municipalities have conducted a Hazard Identification and Risk Assessment (HIRA) for their area of responsibility. The ranking level for pipelines in each community varies. The NEB observed that the community that evaluated pipelines as a higher risk also has a higher level of satisfaction with amount of engagement with the company.First responders in South Stormont confirmed that they have emergency contact information for the company, as well as access to their contractor in the area. They indicated that having more information about the company and its procedures increases their confidence in the company’s response capabilities. First responders in Burlington were not aware of the emergency contact information for the company and said that they would expect their corporate communications / dispatch to have this information.All municipal first responders that the NEB spoke said that they felt comfortable in responding to an emergency on the pipeline within their capabilities, noting that their emphasis will be on public safety.
Observation 3 - Continuing Education
TNPI described its continuing education program to NEB staff. The company told the NEB that it uses its assessment of risks and location of sensitivities and receptors to determine who is informed on the location of the pipeline, potential emergency situations involving the pipeline and safety procedures to be followed in the case of an emergency. Education materials are sent by direct mail to pipeline landowners and pipeline neighbours (neighbours are those residents located within a 200 metre radius of the pipeline). These materials include a brochure on Pipeline Safety, a copy of TNPI’s community newsletter, information on damage prevention in relation to ground disturbance activities, tips on identifying a potential pipeline leak and what actions to take, including reporting suspected leaks to the company. Pipeline landowners are sent information annually, and pipeline neighbours are sent information every two years (with the exception of neighbours along the Hydro One corridor that runs from the GTA to Kingston, who receive information annually). Based on returned mail, the company estimates that it reaches 90% of properties on its contact lists. Information is also shared during committee meetings, conferences and trade shows such as the Ontario Joint Pipeline Committee, Ontario Regional Common Ground Alliance and the Rural Ontario Municipal Association.The company reported that it has received requests for information, primarily through its Stakeholder and Community Awareness website and occasionally through its 24/7 Call Centre. Incoming requests are logged and tracked for action. For example, the company heard concerns from a Scarborough resident and subsequently met with them to discuss emergency response.The company informed NEB staff that they engaged FireMaster as a contractor last year and set up information sessions with first responders in areas where the tank terminals are located, including the Township of South Stormont, to talk about planned response actions and equipment in the event of a fire at these locations. In order to assess the effectiveness of continuing education products, the company told the NEB that it conducts surveys every two years. The 2017 survey conducted by Sentis indicated that some updates to their printed material was required. In response to this the company initiated a bi-annual External Communication Newsletter. The Winter 2019 newsletter provided information on the full scale exercise which was held in November 2018, pipeline safety information and a list of the locations of upcoming preventative maintenance activities. The company reported that it is working on an Emergency Response Fact Sheet, which will be published in English and in French.Representatives of agencies that the NEB met with in Burlington could not recall ever receiving training from TNPI. They reported knowledge of the location of TNPI’s pipeline, but felt that this was more a result of acquired knowledge through years of service as opposed to direct and regular engagement by the company. They stated that new captains may not know where the pipelines are and that they would benefit from having training on first actions to take in the event of a leak, company expectations of the fire department, what the fire department can expect from the company, contact numbers and timing of initial response actions. There was an interest in bringing information to on-duty crews every other year as they feel that there has been no interaction at the grassroots level. TNPI provided confirmation to NEB that they are currently working with the City's Training and HazMat officials to schedule training. This planning started prior to the inspection activity.
Outil de conformité employé : Demande de renseignements (DR)
Exigence réglementaire :
Article(s) pertinent(s) :
Mesure requise de la société :
TNPI is requested to provide confirmation to the NEB that they have spoken with the Burlington Fire Department regarding their continuing education needs relating to a potential emergency involving TNPI's liquids pipelines.
Échéance : 2019-03-25
Date de fermeture : 2019-03-11 Note : La « date de fermeture » correspond à la date à laquelle l’inspecteur de l’Office a déterminé que les mesures correctives prises par la société étaient adéquates et qu’aucune autre mesure n’était nécessaire.
Motif de la fermeture : La mesure a été entièrement accordée.
Conformité atteinte : Oui
Observation 4 - Interoperability
NEB Staff and TNPI discussed how the company works to ensure integration and communication between the company and response agencies during an incident. The company stated that it uses the Incident Command System (ICS) as a tool to manage its response to a pipeline emergency. Within Ontario, which was the geographic scope of this compliance verification activity, provincial and municipal response agencies use the Incident Management System (IMS) which the company reports is similar to, and compatible with ICS. First responders also indicated familiarity with both systems and noted that, in the event of a pipeline emergency involving TNPI assets, they would respond in a Unified Command. During the recent Concept and Objectives meeting for the company’s next full scale exercise the company received feedback from the Bay of Quinte authorities that they are also trained in ICS.Joint communications and Unified Command have been tested during emergency response exercises over the past 6 years, including during the full scale exercise held in Burlington in December 2015. South Stormont informed the NEB that they will be jointly planning a table top exercise with TNPI for later in 2019. It is anticipated that this exercise will include a field component and will engage the Township and provincial departments (OPP, Ontario Ministry of the Environment, Conservation and Parks, etc.).The company trains and conducts exercises with spill response companies and other consultants, such as GHD and Stantec. Burlington noted that some of the contractors that it would engage to assist in mitigation to a hazardous materials spill are the same as those the company uses. The company stated that it provides maps of receptors and control points to agencies, and that its Emergency Procedures Manual is available on its public website. One municipality reported having a hard copy of the company EPM and mapping information, the other did not have this information but was in the process of requesting it from the company.TNPI holds two tabletop exercises a year in Ontario, and a full-scale is held every three years. The last full scale exercise in Ontario that TNPI participated in was Elaion Response East, which was a DND-led exercise that was held in the GTA in 2016.
Les situations de non-conformité se rattachant aux plans ou procédures de la société constituent un non-respect :
- de la condition d’une autorisation exigeant la mise en œuvre du plan ou de la procédure; ou
- de l’article pertinent de la réglementation, qui exige la mise en œuvre du plan ou de la procédure, y compris les articles exigeant la mise en œuvre des plans ou procédures dans le cadre d’un programme.