Compliance Verification Activity Report: CV2021-494 - Alliance Pipeline Ltd.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-494
Start date: 2020-10-22
End date: 2020-10-22


Regulated company: Alliance Pipeline Ltd.

Operating company: Enbridge Alliance Canada Management Inc.

Province(s) / Territory(s):


Rationale and scope:

To verify response capabilities through the assessment of a table top exercise.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Alliance Pipeline Limited Table Top Exercise

Discipline: Emergency Management




Exercise Planning and Conduct
An Emergency Management Exercise Evaluation Team from the Canada Energy Regulator (CER) attended a virtual table top exercise hosted by Alliance Pipelines Ltd on 22 October 2020. Participants attended via an online platform and in person from the company’s Grande Prairie office.  The team consisted of an Inspection Officer (IO) and two CER Emergency Management Specialists. An Exercise Plan and package were available and shared with all participants including the CER before and during the exercise. Other attendees included company participants and facilitators.  
The exercise involved Alliance’s BC-AB Gathering Area operations personnel and management who were in attendance for this discussion based scenario.  The purpose of this exercise was to evaluate the company’s response to an emergency incident.  The exercise objectives included testing the activation of area security response and awareness procedures, testing the activation of the emergency response plan, and testing communications. The CER staff noted that not all of the objectives were specifically stated, thus more difficult to measure and evaluate.
The Evaluation team attended to confirm that company emergency processes and procedures were utilized during the training exercise.  The documents followed by company staff covered safety, communications, and system operation procedures for use during emergencies.  
As noted above, the exercise was held virtually and in a local meeting room in Grand Prairie, AB.  Participants were presented with the initial scenario as a group and asked to talk through the prescribed company response actions/steps for the scenario presented.  Further exercise injects were made verbally and via PPT slides shown by the facilitator to present opportunities for participants to react and guide participants towards expected actions and task completion.
Notification and Reporting 
Internal notifications were accomplished as prescribed in the company emergency response manual. Company Gas Control was contacted as well as the local area technicians group.
External notifications consisted of contacting the RCMP via 911 (discussed only, not simulated). CER staff noted that this was completed very late in the response and for the scenario exercised, should be completed immediately. Notification of local county and municipal contacts was also discussed. No other notifications were discussed. CER staff did outline the procedures and requirements of contacting the CER/TSB for notification of such an incident. The one window reporting and use of the OERS system was discussed as a useful tool to gain familiarity with during an exercise.
Safety of participants was discussed at the beginning of the exercise. Alarms, muster points and exits were explained by the facilitator for the office staff and virtual attendees. As this was an office and virtual based exercise, no PPE or related field safety equipment was required.  COVID protocols and safety measures were discussed at the beginning of the exercise. COVID safety measures were implemented through: the virtual nature of the exercise, the restriction of travel, exercise set up with the GPP office and office COVID safety measures for office attendees. At the start the exercise scenario those in attendance were reminded to remain compliant with COVID protocols through the duration of the exercise.
The safety of company staff who would have been in the field in a real event was discussed during the initial phase of the exercise. Covid-related PPE and expectations for a potential field response were not discussed. CER staff noted this would have been a good opportunity for the company to incorporate field-based Covid protocols and share response specific pandemic prevention information.  The IO noted that the tactics discussed for reacting to the scenario appeared to be lacking in safety considerations. People, Environment, Assets and Reputation (PEAR) was introduced by the facilitator at the beginning of the exercise and was repeated throughout the exercise to identify ‘people’ as the first priority. The expectation to evacuate, alarm, notify law enforcement, was not observed to be the primary and immediate response priorities by participants. The facilitator was in a good position to identify this as one of the first actions after giving participants a chance to discuss and form the initial response. 
Exercise participant’s regard for staff and responder safety, given the specific scenario, was low despite the facilitator’s numerous attempts to guide them towards this primary response objective and priority for any emergency. The decision to evacuate the immediate area was late in the response and towards the end of the exercise.  CER staff noted this decision was inappropriately delayed as the potential consequences relating to detonation of a device within a gas plant would likely have very wide reaching effects.  Mention of public safety was only observed late in the exercise and this was considered inadequate by CER staff as it should be one of the first priorities and objectives to be considered in any response. The level of alert was also only considered towards the end of the exercise.  The Level of alert (also referred to as incident classification) should be one of the first response actions and could help dictate many other response actions as outlined in company plans.
 Response Management and Tactics
At the onset of the Incident, company staff (staff) began discussing their initial actions. The scenario was that initial staff at site noticed a suspicious package on the pipeline at the facility.  Field staff began discussing their initial actions and were reminded by the facilitator to be detailed in their discussion of preparations and hazard considerations they would undertake in an actual event.
Company Area Security Response and Awareness Procedures outlined the proper steps company personnel should take upon discovering a security threat. They were as follows:

  1. Report the suspicious package (does it look out of place? Old or new? Damage or odd features of the package noticeable? Is noise coming from the package?)
  2. Prioritize actions with safety as the first priority, followed by incident stabilization and property & environmental preservation
  3. Make safe and secure any hazards to life and property by implementing specific security and emergency response procedures
  4. Call 911 and give information
  5. Notify Gas Control
  6. Notify internal and external affairs through the company “on call” system
  7. Notify Emergency response and security group (ER&S) and Enterprise Security
  8. Coordinate with external emergency response agencies as applicable
  9. Document actual security incidents using EnCompass Incident Reporting Tool
  10. Coordinate security investigation with ER&S Group
    For the exercise, staff’s actual initial actions were to take a photo of the package to send to an “area techs” internal group to ask what it might be, and to alert other staff and supervisors of the situation simultaneously. It was discussed that not all technicians and staff would have the ability to do this due to differences in equipment between staff.  The use of photographs was a smart and quick way to capture information about the package for further review while maintaining personal safety for the operator.
    Field staff then said they would start going through their threat checklist and notify gas control to isolate the site. They would also ask gas control to confirm if they were contacting local neighbors. It appeared that there were two different sets of bomb threat procedures, one being an older Alliance document and the other a new Enbridge document, which CER staff noted could be confusing.
    It appeared to CER staff that the initial actions the responders were taking did not involve as much consideration for life safety and preservation. Responders instead focused on trying to decipher what the package may be and if the threat was credible or not. CER staff are of the view that every safety precaution and actions should be taken immediately during any situation with the potential to be harmful to life safety, regardless if the threat is real or false.
    Company staff then agreed they would next self-evacuate from the site and parked their vehicle to call their supervisor. The facilitator coached staff through the activation of the ERP and discussed that an Incident Commander would need to be appointed. CER staff noted that while field staff were very competent in their operational abilities, some staff self-identified that they were not well versed in using the company ERP or response tools, or well versed in Incident Command System (ICS) roles and responsibilities.  Staff stated they would then find an offsite location for a mobile ICP to be established. Safety of staff, public and responders was discussed but not in depth and perhaps taken too lightly in the situation exercised. CER staff noted there was a lack of urgency or understanding in why establishing a level of emergency was important and there was limited understanding of who would be involved in Unified Command.
It was discussed by staff that if the area surrounding the facility required evacuation, the area roads would get congested quickly and communications may get complicated. Other staff began thinking that nearby facilities may have cameras set up that would capture evidence of who may have left the device. CER notes that RCMP would be an appropriate resource to conduct these activities as they have authority to close roadways, redirect traffic, investigate the incident and even bring in bomb technicians. RCMP familiarity with outside agencies and their roles and capabilities would be beneficial to all staff and the overall response. 

Staff discussed the potential for a unified command with the RCMP but did not discuss the reasoning. No other organizations or agencies were discussed in regards to notification or unified command.  Approximately an hour into the exercise, there was an exercise inject that the bomb then went off.  Discussions now turned to securing the site and involving RCMP and night shift security. They did not discuss the impacts of the explosion or any tracking or media interest.
CER staff noted that the response discussion was a bit scattered in its approach, that some response steps were missed initially and then remembered later, and ICS tools and terminology were underutilized.  One of the objectives of the exercise was to fill ICS roles and aside from appointing an Incident Commander, no other roles were filled. 
Post Exercise 
Overall, CER staff are of the view the table top exercise objectives were partially met. The participants had good discussions and completed a walk through or talk through of what they would be doing as it related to the exercise scenario. They utilized the internal response tools for guidance when prompted and eventually reached an appropriate course of actions.
However, CER staff had safety concerns as participants appeared to be prepared to engage in unsafe activities.  For instance, some actions involved getting too close to the threat and were concerned with determining what was going on over implementing caution and safety measures. Following the exercise it was disclosed that in a previous exercise with a similar scenario they had identified that adding binoculars to the truck kits would allow them to assess the situation from a safe distance.  These binoculars were purchased and added to the truck kits yet were not discussed as a possible safer option to assess the situation from a distance.  Lack of awareness of changes to response equipment resulted in a missed opportunity to implement the learnings from a previous exercise.
CER staff noted that the table top scenario was realistic but could include an established timeline for events to demonstrate how realistic actions being discussed would be and how long they would take. The objectives to test activation of area security response and awareness procedures and activation of the ERP and its associated tools were completed, however, required more time than standard industry practice and much prompting by the facilitators. The objective to test communications was partially met as the regulatory agencies were not discussed to be notified or contacted during the exercise. CER staff is concerned that other agencies would be missed during notifications and reporting as well based on this outcome.
Exercise participants felt that they worked together well to collaborate and execute a response. Participants did comment that they felt the response approach lacked organization and structure. The participants used ICS forms during the exercise to practice and familiarize themselves with them, however, other aspects of ICS were not used such as assigning staff roles. CER staff are of the view that more ICS training and familiarization with all company staff would greatly increase the organization of the response and its progression.  More use of ICS would also allow roles and functions to be identified and assigned and unified command to be established involving the most applicable and appropriate resources. 
Participants benefited from learning what they did not know about this particular facility and the exercise highlighted for them the need for more response training. In particular, training on the various internal tools and applications available and training in ICS was needed.
The exercise also highlighted the need for company response plans to be updated and old information removed from them e.g. the two different sets of bomb threat information still in use. As well, the company needs to ensure if using cell phones and satellite phones for communications that coverage is available in all areas they are relied upon. It was discussed during this exercise that coverage for the exercise location is spotty and not reliable. Facility specifics such as these need to be reviewed regularly and kept current in all emergency response plans, updated plans reduces confusion and time during emergencies. It was also noted that not all employees have the same cell phones and the emergency response App and tools may not be compatible with all types of phones. This is an important detail when building response tools and procedures. Company-wide, or at least responder-wide, compatibility and accessibility is paramount during an emergency.

Alliance Pipelines Ltd. is requested to file an After Action Report.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Alliance is requested to file an After Action Report (AAR). Follow instructions in the Documents section to upload and submit the After Action Report by February 15th 2021. The AAR should describe:

-              the exercise scenario

-              player activities

-              preliminary observations

-              what could be improved on, based on:

o             observations and learnings from all exercise participants

o             recommendations for each observation/learning, or

o             an explanation as to why a recommendation/feedback will not, be addressed.

-              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: 2021-02-15

Date closed: 2021-02-18
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

Observation 2 - CER Observations

Date & time of visit: 2020-10-22 08:00

Discipline: Emergency Management




CER staff are of the view that consideration of the following observations would benefit the company: 

  1. Obtain additional exercise design capacity and develop “SMART” exercise objectives and measurable evaluation criteria. The company may benefit from having an external party to help develop and facilitate future exercises.
  2. Include at least a couple of key stakeholders in exercise design and play (most relevant to scenario)
  3. Review the expected and the most ‘right’ actions after the exercise, instead of at the beginning, to help ensure that that the largest response gaps are filled before participants leave the room.
  4. Review and consolidate existing protocols (e.g.: Two different Bomb Threat response protocols were utilized) to ensure that the proper protocols are being used.
  5. Review and clarify the roles and responsibilities of site staff vs. supporting EOC staff, as well as review the ERP list of expected response actions. With assigned roles exercised, staff will gain more experience and understanding of how their role and responsibilities fit in with an emergency response and management system.
  6. Create a thorough ICS and ERP training session and schedule for all company staff (especially those responding)
CER staff will review the Action Action Report to ensure that the CER observations have been considered.
Additional compliance verification activities have been planned, including an implementation assessment and attendance at the next Full Scale exercise, to ensure Alliance has addressed the gaps identified during this exercise.

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