Compliance Verification Activity Report: CV2122-252 - Plains Midstream Canada ULC


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-252
Start date: 2021-04-09
End date: 2021-04-09


Regulated company: Plains Midstream Canada ULC

Operating company: Plains Midstream Canada ULC

Province(s) / Territory(s):


Rationale and scope:

To verify response capabilities during Plains' Full Scale exercise on their Eastern Area Pipelines in Ontario. The exercise is scheduled for 9 April 2021. The exact location, scope, objectives and participants will be determined at a later date. Lessons learnt during the previous CER evaluated exercise CV1920-417 included: some equipment not being functional, having a pre-printed list of vendors, to help reduce ordering time, needing more practice with 207 forms and more training with response equipment, needing more involvement with local authorities to use existing knowledge, tools, evac plans, and reception centers that locals are already familiar with, and visually delineate hot, warm and cold zones more clearly.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Windsor Full Scale Exercise - Emergency Response Exercise Evaluation

Date & time of visit: 2021-04-09 10:30

Discipline: Emergency Management




Exercise Planning and Design 
The Canada Energy Regulator (CER) attended a virtual full-scale exercise conducted by Plains Midstream Canada (PMC) on April 9, 2021. Attendees outside of company personnel consisted of three CER Emergency Management Officers, two fire and rescue and four hazmat first responders from Windsor, Ontario. The CER was provided an exercise briefing document in advance of the exercise outlining: scenario, objectives, exercise rules, and a detailed breakdown of scenario injects. The exercise objectives were to: 

  • Plan and record initial actions via an Incident Command System (ICS) 201 Form; 

  • Practice key roles and responsibilities for Command Staff and General Staff; 

  • Conduct an Incident Briefing; 

  • Test a response using the Virtual Incident Command Post (VICP); 

  • Test the deployment of public protection actions; and 

  • Utilize and evaluate the Emergency Response Plan. 

CER staff were provided access to PMC’s Emergency Response Portal in advance of the exercise allowing time to become familiar with the layout of the company’s VICP and their virtual Emergency Operations Centre. The exercise scenario and objectives were appropriate for PMC’s exercise program. The specific objective of familiarizing company staff and the regulator with tools used to facilitate virtual response team integration and support during an incident is a positive step towards increased remote response capabilities. All supplied documents from PMC provided adequate information of the training. 
The initiating event for the exercise was a lost connection at the loading rack, resulting in a flailing hose that injured the loading operator and launched a broken fitting towards the mercaptan tank causing damage and subsequent uncontrolled release of ethyl mercaptan. This scenario provided PMC with a sufficiently detailed and complex situation in which the objectives could be achieved. 
Exercise Facilitation and Control 
PMC developed and discussed the exercise briefing document in detail with all participants and observers prior to starting the exercise. The briefing outlined exercise schedule, rules, external notification restrictions, and controls. Being a virtual response, PMC facilitators described how exercise injects would be managed and controlled - ensuring progression of response tactics and an environment to achieve the exercise objectives. The overall facilitation and control of the exercise was conducted by the company.  
Notification and Reporting 
PMC responders utilized their internal ‘initial response checklist’ located within the emergency response plan which guided them through making essential notifications to initial responders and regulatory authorities. PMC responders also used the applicable responder checklists which outline internal and external role specific responsibilities. These two documents supported each other and the response; there were interwoven prompts to ensure all required notifications are completed. This was observed throughout the exercise while responders were seen coherently working together towards the response goals and requirements. The internal notification aspect of the PMC response and quick task assignments from the Incident Commander (IC) allowed for a ‘get big fast’ response providing an influx of resources to the incident location. Further internal notifications were completed by the Safety Officer. 
PMC staff used the single window incident reporting by calling the Transportation Safety Board to report the incident, who in turn notified the CER. The phone notification is required to occur as soon as possible and no later than three hours of the incident being discovered in order to allow the relevant agencies to assess the incident and mobilize a response, if required. Following the confirmation of the incident, PMC conducted the necessary notifications and provided the CER with accurate information. 
Internal notifications were observed to be a strength in the PMC response.  This appeared to be a function of adherence to the documented internal procedures and responder teamwork. 
Safety of personnel during an emergency is paramount to any response. During the exercise, the IC and responders took overall safety and safety protocols seriously which is important to point out considering that they were responding to a simulated emergency using virtual meeting technology. Initial actions following the discovery of the ethyl mercaptan leak and injured employee included the immediate shut down of the facility and mustering of personnel on site. This was followed by a head count ensuring all personnel were accounted for. 
The IC’s top priority for the response was life safety.  A Safety Officer was assigned by the IC to: 

  • Ensure that the incident commander understands that job hazard assessments will be completed prior to deployment of the air monitoring and rescue teams; 

  • Upload a Ethyl Mercaptan Safety Data Sheet (SDS) to the VICP; and 

  • Send Plains Incident Notification system internal distribution email to notify all impacted individuals of the situation. 

Overall, key messaging from the Safety Officer was focused on ensuring that all responders knew that life safety was identified as priority over control of situation. 
Following the initial safety response measures detailed above, the Safety Officer proceeded completing job hazard assessments for all major response actions including recovery of injured personnel, objectives pertaining to the prevention of additional leakage from the tank, removing remaining product, and prolonged air monitoring for the surrounding area. CER staff observed that the safety data sheet for ethyl mercaptan was uploaded to the VICP. Information from the safety data sheet was included in the job hazard assessment but a verbal review of this information with impacted responders was not observed.  

Development of the Health and Safety Plan was completed within the first hour of the exercise. The document contained sufficient detail and covered all required aspects of the plan for the initial response period. CER staff reviewed the plan and noted that “the need for respiratory protection will be determined by the Safety Officer after review of SDS and air monitoring data retrieved from the initial site assessment”. Requirements for respiratory protection were included in the Health and Safety Plan as well as the job hazard assessment the CER did not observe a formal discussion with responders regarding these expectations.  

The CER observes that it is difficult to effectively evaluate some components of a hybrid-style exercise using only virtual presence, particularly those elements of the response that occurred on site that the CER was not present for. 

The Health and Safety Plan also addressed hazards associated with remote response efforts though the VICP. 

Response Management 
PMC has adopted ICS as its incident management system for providing a structured approach to responding to an emergency.  Given the restriction on in-person gatherings due to the pandemic, PMC created a VICP and Virtual Emergency Operations Center (VEOC) online.  CER staff were given access to this platform for the exercise and observed that it contained helpful reference information, including the site emergency response plan, the exercise briefing documents and a samples of ICS forms that could be downloaded and updated with incident-specific data. CER staff observed that several ICS forms were already populated in the VICP for the exercise, such as personal logs, an organization chart, the SDS for ethyl mercaptan, and the work analysis matrix. Some of the nomenclature used to save the forms varied (initial followed by last name, first name last name and last name) and in one instance the same form was completed and uploaded by two different people (with two different naming conventions). To avoid confusion and reduce the risk of responders using outdated information or duplicating effort, it is encouraged that PMC determine a standard naming convention for all forms. 
Channels in the virtual software were used to simulate sections in the ICS structure. The virtual platform provided a means for responders to continuously fill out and update necessary forms that supported the ongoing response and provided effective recordkeeping. Responders referred to the Windsor Storage Terminal Emergency Response Plan (ERP) for reviewing incident classifications and actions to take for each level of incident. 

During the initial phases of the response, the basic elements of incident management were followed. ICS roles were immediately designated, and a chain of command and flow of information was established. Sample ICS forms were uploaded to the VICP for use by all responders. While responders worked through the emergency response plan the following actions were completed: 

  •  Development of incident objectives; 
  • Establishment of an operational period; and 

  • Utilization of support documentation. 

 The IC gave explicit instructions throughout the response to the Command and General Staff as they were assigned to the incident. There was a clear understanding of expectations and deliverables. At the onset of the incident, response priorities and objectives were quickly identified. Despite identifying objectives early, the objectives detailed in the initial ICS 201 form did not meet the generally accepted criteria for SMART objectives, that is: specific, measurable, achievable, relevant, and time bound. SMART objectives were developed later in the response when PMC responders began working through the ICS 234 form. PMC should practice developing SMART objectives initially in the response while utilizing the ICS 201 form to ensure a smooth transition of intent for potentially longer responses.  

The incident management team operated in a calm and productive manner throughout the incident while utilizing emergency management resources such as their emergency response plans, virtual response channels, ICS organizational charts, and ICS forms. This fostered an environment that allowed for easy delegation of roles, productive discussion, and teamwork. 
Overall, PMC has a good understanding of their response management system and demonstrated that they could respond virtually in an effective and competent manner. 
Response Communications Technology 
Reliable and effective communication is essential to the success of any emergency response. Passing information and making informed decisions between operation centers, response channels and external stakeholders is important for an effective response. PMC utilized online technology to have an open line accessible to all responders. This line was kept open throughout the duration of the response but was utilized for the most part as a radio.  Responders used radio procedures such as starting a discussion by naming the intended recipient’s position followed by the caller’s position. This worked well to ensure clear intent and direction of communication as well as reducing confusion. The response team also utilized the same means to schedule and accommodate team meetings where they exchanged information and established objectives, strategies, and tactics. 
External Communications (Public, Landowner, Stakeholder, and Indigenous Nations) 
At the onset of the incident, the IC activated the Liaison Officer who began notifying local agencies and informing them of the situation and providing any specific details impacting their constituents or infrastructure. The CER, Windsor Fire & Rescue Services, and the Ontario Ministry of Environment and Climate Change were the first notified of the incident which is consistent with what is outlined within the emergency response plan. The Public Information Officer was also activated early in the response and worked to identify stakeholders potentially impacted by the incident. The Public Information Officer consulted with the CER and Windsor Fire & Rescue Services to develop a media release to inform residents and the general public with accurate and consistent information. The company’s Crisis Communications Manual was also activated; this outlines crisis communication resources, procedures and protocols which will be discussed in detail later under Public Protection Measures. 
Tactical and Strategic Response 
In conjunction with PMC’s emergency response plan, PMC responder knowledge and experience provided a condition in which response tactics and strategies were developed and actioned in a proficient manner. At the onset of the incident, involving an unconscious worker next to an ethyl mercaptan leak from a vessel, workers immediately shut-in the facility and mustered.  A head count was conducted identifying that one member was missing. Activation of the VICP was immediate. Field staff began developing a plan to safely retrieve the casualty, which included establishing safe zones for rescue operations and utilizing site personnel for initial gas monitoring. 

PMC responders were quick to establish the following response actions: 

  •  Establish safe zones for rescuing injured personnel and demarcate the hot and warm zones. 
  • Two site personnel were dispatched to monitor and confirm safe atmosphere for the rescue of the injured worker. 

  • Conduct the rescue following establishment of safe zones. 

  • Activate offsite resources, if necessary. 

  • Two site personnel establish safe work zone (0 LEL) and rescue the injured worker. and 

  • Await safe extraction path to outside medical services. 

 While recovery operations were being developed, the VICP began initial internal and external notifications while developing a strategy to conduct air monitoring around the perimeter of the facility. By implementing air monitoring early in the response, PMC was able to use this information to establish hot, warm, and cold response zones which shaped response efforts moving forward. 
The ‘initial response checklist’, found within the emergency response plan, was utilized by the IC and Deputy IC to assist with ensuring that required response actions were being initiated and executed. The ‘initial response checklist’ is broken down into the following categories: 


  • Initial actions and assessments 

  • Document initial actions 

  • Level of emergency 

  • Incident details 

  • Activate emergency response protocols 

  • Incident briefing and next steps 

Following attainment of the initial response objectives, the updated response objectives focused on the leaking tank and continued responder and public safety. Vacuum trucks and extra self-contained breathing apparatuses were mobilized to site while PMC responders constructed a vapour spray system to apply water to the tank reducing additional air contaminants. Efforts were also made to redirect product to flare. Once PMC responders flared as much product as they could, the vacuum trucks were dispatched to pump out remaining product from the tank. PMC responders demonstrated sound technical knowledge and application of procedures to remove the remaining product from the vessel. When the vessel pressure was at zero, efforts to seal the hole were initiated. 
PMC responders followed procedures found in the Windsor Emergency Response Plan which outlined response measures and tactics for hazardous material spills. The strategies and tactics taken to respond to the incident were in line with expectations for a competent and efficient response. 
Public Protection 
Ensuring life safety is identified as a PMC incident priority along with incident stabilization and minimizing impacts. These priorities are incorporated within the PMC emergency response plans and supporting documents and tools. The ‘initial response checklist’ prompted responders to secure the incident area, which ensures protecting the responders and surrounding public by isolating the hazard area and setting up air monitoring. During the initial phases of the PMC response, CER staff noted that these actions were immediately discussed by the incident management team. The IMT identified that a request would be made to the local police to assist with roadblocks at key locations to prevent access to the incident site and to areas where air quality was of potential concern. One of the response objectives was to conduct air monitoring for purposes of public safety around the site perimeter.  The air monitoring plan was quickly organized and included direction to establish monitoring sites along the facility fence line and in surrounding community areas. A business and a public park that were in close proximity were identified as priorities for evacuation. When facilitators submitted an inject that air monitoring readings were identifying potential areas of concern, discussions to expand the isolated area took place. 
Post Emergency Phase 
CER staff are of the view that the exercise objectives were met. The simulated response included a small field component with enhanced support through the VICP. Exercise participants appeared to play out the appropriate processes and procedures as if it was a real incident. The exercise was realistic, process driven and effectively accomplished all objectives set by the facilitators. The response structure and virtual software implemented by PMC was used effectively and provided virtual responders with experience in its strengths and limitations. 
Other Considerations: Virtual Environment 
CER staff were unable to access the virtual meeting space for the exercise and PMC had to facilitate a workaround. Effective integration of external parties will be required during a response, including first responders, local authorities, government agencies and regulators. PMC should identify and improve options for integration of non-company parties into its VICP and other virtual tools/platforms. 
It took 15 minutes for CER staff to obtain access to observe the virtual meeting space for the exercise since they did not have the Skype for Business application on the CER computers and that was the application that the company used to communicate.  PMC was able to facilitate a work around by using MS Teams to share their screen with the IOs.  This served the purpose for the exercise but would be insufficient for the CER to conduct oversight of an actual response operation.  

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):

- The Safety Data Sheet was uploaded to the Virtual Incident Command Post (VICP), but there was no review of the specific hazards with responders. Product specific hazards should be discussed with all responders within a safety or job hazard assessment meeting prior to execution of response tactics.

- Nomenclature used to save completed forms within the VICP varied depending on who was submitting them making it sometime difficult to find required information. Plain Midstream Canada (PMC) should utilize a standard naming convention to reduce time required to find essential information.

- Even though objectives were identified and actioned for this scenario, PMC should practice developing SMART (specific, measurable, attainable, relevant, time-based) objectives required to respond to prolonged and more complicated incidents.

- Effective integration of external parties will be required during a response, including first responders, local authorities, government agencies and regulators. PMC should identify and improve options for integration of non-company parties into its VICP and other virtual tools/platforms.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Plains Midstream Canada is requested to file an After Action Report (AAR).

Follow instructions in the Documents section to upload and submit the AAR by August 27th 2021. The AAR should describe:
-        the exercise scenario
-        player activities
-        preliminary observations
-        what could be improved on, based on

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: 2021-10-25

Date closed: 2021-11-01
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