Compliance Verification Activity Report: CV2021-474 - LBX Pipeline Ltd.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-474
Start date: 2020-09-15
End date: 2020-09-15


Regulated company: LBX Pipeline Ltd.

Operating company: LBX Pipeline Ltd.

Province(s) / Territory(s):


Rationale and scope:

To verify response capabilities through the assessment of a full scale exercise. CER staff have not previously seen a full scale exercise conducted by LBX as they have been done under Husky.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Exercise Observations

Date & time of visit: 2020-09-15 08:00

Discipline: Emergency Management




Exercise Planning and Conduct

An Emergency Management Exercise Evaluation Team of the Canada Energy Regulator (CER) attended a full scale exercise organized by LBX Pipeline Ltd. (LBX) in Lloydminster AB, 15 September, 2020.
The CER team consisted of two members where one was observing the exercise within the company’s Incident Command Post (ICP), and the second member in the field. The exercise was conducted to meet the company’s requirement demonstrating compliance to s.32 of the Onshore Pipeline Regulations and Clause of CSA Z662-19. Specific COVID-19 guidance measures. A situation manual and an exercise plan were available and shared with the CER before and during the exercise.

The exercise was designed to incorporate the Midstream ICP, Crisis Response Management Team (CRMT), Pipeline Control Room, emergency call out system, and Spill Response Team. The objectives for this exercise were set out by LBX and were attainable, measurable and realistic for this scenario. The exercise appeared to be designed in consideration of the hazards and risks posed by the company’s operations. The simulated scenario included a pipeline release of blended crude into the Battle River. This set up created a situation where a LBX Spill Response Team could practice efficient boom deployment whilst members of the ICP managed downstream impacts, resource and communication management, as well as planning and development of an incident action plan.
The exercise objectives consisted of the following:  

A pre-exercise orientation occurred at the ICP as well as the Spill Response Team’s deployment location. The orientation included site emergency procedures, COVID 19 procedures and particular situations that would result in suspension of the exercise to reallocate resources to an actual emergency event. At the location of the boom deployment, park rules were reviewed as well as specific safety concerns and procedures relating to terrain, working near water and weather conditions. In addition, exercise ground rules were also discussed which included the use of a Simulation Cell (Sim-Cell) during the training which simulated residents, government agencies, third party vendors and emergency services.

Notification and Reporting

LBX initiated the incident by testing their emergency call out contractor. Once the event was processed by the call out contractor, LBX staff immediately began receiving the emergency notifications. Once the Incident Command Team (ICT) received the alert, they mustered to the ICP. Further notifications from the ICP were completed in an orderly fashion as outlined within their Emergency Procedures Manual (EPM).
The ICT deployed responders to the incident site to confirm the release and promptly set up an On-Site Command Post (OSCP) and established a comprehensive and systematic schedule of meetings to ensure incident information was being promptly relayed to the ICP. Information from the OSCP pertaining to the incident was documented within the ICS 201 Incident Briefing Form and utilized when completing the required external agency notifications.
The CER observers witnessed LBX completing all primary and secondary government notifications as well as informing other stakeholders. LBX responders also quickly identified the possible effect to drinking water contamination downstream within Canadian Forces Base (CFB) Wainwright as it provides potable water to the surrounding communities. Immediate notification to CFB Wainwright was completed to inform and discuss planning to prevent water shortages. This action provided CER staff insight into LBX’s ability to utilize their site specific EPM’s and determine specific contingency planning and notifications outside of the more generic response notification processes and procedures.  


Safety instructions were reviewed during the pre-exercise briefing held over a conference call, attendees included all individuals participating within the OSCP, ICP and CRMT. Further to the specific exercise safety instructions, LBX also explained and discussed the COVID -19 protocols, regular LBX safety procedures and indicated that they will be followed during this response exercise. Rules for a real incident were highlighted to ensure that in the event of an actual emergency situation or injury, a full-stop to the exercise will follow and response to the actual incident will occur.
The Spill Response Team Safety Officer, located at the boom deployment site conducted their own operations and safety briefing prior to the exercise. The safety briefing was consistent with the main speaking points discussed at the ICP but included site specific safety points such as:
Further to the operation and safety briefings conducted by the Spill Response Team, the Team was encouraged to review the LBX Geographical Response Plan (GRP) for that specific location to familiarize themselves with boom deployment strategy and location specific concerns.
Response Management
The exercise began with the control room operator receiving an alarm indicating a possible leak. The potential incident was reported to the call out system which then notified the larger response team. The call was received by all intended participants that were involved with the exercise. Members of the ICT mustered at the ICP and the Incident Commander (IC) patiently waited for all responders to come into the room before starting any discussions to ensure all responders were up to date. Following the initial briefing conducted by the IC, they promptly designated roles and responsibilities to the other responders and ICS colour coded vest were issued as required.  Following team organization, the IC re-organized the seating arrangement within the ICP placing the more vital roles closer to where they were and the support roles further to the rear of the room. This organization of teams was seen by CER staff to promote required conversations and allow functionality for working through the planning and response processes.
Following the confirmation of the release, the IC activated the OSCP and CMRT. Call in times were organized to ensure the staggering of information sharing between the OSCP and ICP, and the ICP and CMRT. For the purposes of this exercise, the OSCP was located in the same building as the ICP but was located in a separate office to simulate realism.
At the onset of the incident, LBX began working their way through the ‘Planning P’ as outlined within the EPM. The ‘Planning P’ is a common emergency management process that models incident management processes for an operational period.  For smaller incidents such as the one for this exercise, a company can just work your way through the stem of the ‘Planning P’, the mini P without getting into the cyclical response operational periods.
LBX responders determined the level of emergency to be level three. Emergency level 3 response protocols were completed as described with the EPM.
CER staff noticed that the response priorities and objectives were quickly identified and were consistently updated as the scenario progressed through many different inputs from the facilitators. At the onset of the response the Initial objectives were determined to be:
It was observed that the goal and objectives determined were clear and reachable. Each objective being specific, measurable, achievable, relevant, and time bound (SMART). While conducting briefings there was a clear agenda and flow that always concluded with the review and editing of the objectives and setting a timing for the next briefing.
During the first initial planning meetings, it was observed that other officers were preoccupied with their phones and would step out of the room. As part of the pre meeting guidelines set out in the EPM, the Planning Chief needs to clearly set the ground rules prior to the onset of the meeting to ensure everyone is paying attention. Officers and Chiefs need to organize and offset meeting to ensure that they are able to give the planning meetings their undivided attention. Although this did get better in future planning meetings, it is vital for the Planning Chief to set these expectations early on in the response.
The ICP and OSCP were seen to be operating in a very calm and collective manner throughout the incident while utilizing emergency management resources such as their EPM’s, GRP’s, ICS Organizational charts and ICS forms. This allowed for an environment that allowed for easy delegation of roles, productive discussion and teamwork. LBX was seen to have a comfortable understanding of the ICS system and utilized its advantages to streamline a response. This understanding allowed the IC to leave the deputy IC in charge while in meetings updating the CRMT without causing any confusion or interruption to the response.
Response Tactics

Following the incident notification to the response team via the call out system, the IC immediately dispatched responders to the field to confirm the release. Once the release was confirmed and the effected pipeline was identified, it was immediately shut in. Shortly after, responders received a call from a land owner who informed LBX that there was oil in the river downstream of the release.
The IC dispatched responders and different points downstream to determine the extent of the release while concurrently ordering aerial drone assets to more accurately observe the degree of contamination.  The Spill Response Team was activated and mustered at the staging area. OSCP obtained information from their EPM indicating flow rate of the river which gives the ICP information as to where to look where plume may have reached while efforts began on finding the entry point of the contaminant into the river.
Initial objectives were determined to be
In conjunction between the OSCP and ICP, activation of the GRP was completed. The Spill Response Team utilized the Gratton Coulee GRP to find out where the control points were located and any special conditions required to use them. There seemed to be some confusion throughout the response as to the exact location of the spill and which GRP was to be utilized. In this event, the outcome of the response was not compromised with this confusion, but a clearer understanding of the overall situation should be accomplished during future exercise and possible events. The IC and Planning Chief were requesting maps of the area which were quickly printed off by members of the documentation unit, however they were small and partitioned. It was discussed that the use of larger maps in the ICP would have allowed responders to gain a better understanding of the overall impact of the event and aid in response coordination and reduce confusion. 
The Safety Officer was seen to proactively begin working on specific hazard assessment for working near water and ordering safety equipment for performing road blocks and safe boat launching locations.  
Point of Entry into the river was discovered and it was determined that containment at the location could only be accomplished by constructing a bell hole to capture the product before it enters the river. The OSCP requested equipment through the ICP to begin completing the construction of a bell hole to begin recovering contaminants at the source site. 
Following a brief discussion within the ICP, it was realized that the water treatment plant at CFB Wainwright could possibly be effected by this incident. The Liaison Officer notified CFB Wainwright to shut down their water intake on the Battle River as they provide water for the surrounding off-base residential and commercial areas. After shutting the intake, the process of figuring out how to get water to CFB Wainwright and the town of Wainwright began.
New set of objectives identified as:
The Operations Chief and the Planning Chief began conducting tactic meetings to discuss the possible plan of digging a bell hole the point of entrance and begin skimming product at that location to reduce the overall contamination downstream of the event. Ground disturbance and site specific safety plan development was initiated. It is important to note that the Safety Officer was observed slowing down these initiatives until a proper site safety plan was developed and safety and security personnel were on site. This objective also saw the mobilization of heavy equipment such as vacuum and tanker trucks to the staging area to accomplish the objective when ready. Rig mats were also brought to the staging area to reduce the equipment’s impact to the river banks around the bell hole.
The Safety Officer was heard on the phone to the OSCP strictly indicating that no work will be completed around the bell hole until and safety plan has been created and is approved. This was a clear indication to the CER that safety was paramount in this response operations.
Prior to boom deployment a briefing and tactics discussion occurred. The On Scene Commander (OSC) had drawn a river boom deployment diagram with radio channels and roles depicted.  This diagram matched the pre-created visuals in the GRP except slightly to the east to facilitate easier river bank access.  Weather conditions and river current where also discussed. Boom was effectively deployed utilizing 2 boats which were launched into the river and whose crews immediately set two buoys, up and downstream from the boom deployment site to warn other boaters of the exercise. Shoreline protection boom was set completing the task of effective boom deployment.  The CER inspection Officer observed a positive learning environment where staff assisted each other willingly.  

Communications and related equipment were effective and efficient. Overall, LBX staff effectively communicated during the exercise within, and between the OSCP, ICP and CMRT.
The methods of communication used were almost solely via telephone. The initial emergency call-out came through via text from the emergency call-out system and CER staff observed LBX responders utilizing cell phones and conference calls to effectively collect and exchange information.
LBX responders were observed to make all required internal and external notification as outlined in their EPM. This included all required government agencies, third party stakeholders and specifically required venders, contractors and mutual aid partners.

The Liaison role was established in the ICP. The Liaison Officer frequently touched base with the Public Information Officer throughout the exercise to provide updates on the incident as well as the initiatives they were planning. Key messages were discussed at to ensure consistency.
Post Exercise

LBX ICP and OSCP participants were involved in a large group debrief at the conclusion of the exercise. An in depth debrief of the exercise was completed outlining the overall flow of the response as a whole. Than each Team Lead, Chief or Officer was given time to discuss any particular success or struggles experienced during the scenario. This offered the opportunity for other response groups to see how their individual actions affect the greater response efforts throughout the teams.
Following the broad overview, each individual was encouraged to speak about their individual observations and provide positive and negative feedback free of scrutiny. CER staff noted that overall the feedback was positive throughout the response positions but key discussions were sparked leading to lessons learned and related action items.
Overall, this exercise consisted of a very challenging scenario involving many stakeholders and diverse inputs. The CER was  pleased to see a challenging scenario that created an environment on learning and coordination. The Inspection Officer evaluating the Spill Response Team also noticed that they had chosen a difficult deployment location testing their capabilities and procedures.

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