Compliance Verification Activity Report: CV1920-452 - Montreal Pipe Line Limited

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV1920-452
Start date: 2019-10-18
End date: 2019-10-18

Team:

Regulated company: Montreal Pipe Line Limited

Operating company: Montreal Pipe Line Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

As a follow-up to address an AVC regarding the fire protection system of their storage tanks, MPLL is planning a deployment exercise with the Montreal Fire Fighter Department to simulate a tank fire (North Tank Field tanks fire protection system). The exercise will include deploying all necessary equipment (foam tank, hoses, fire trucks) and flow simulated foam in the secondary containment.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Overall Exercise Observations

Date & time of visit: 2019-10-18 14:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Exercise planning and conduct
CER Inspection Officers attended a Montreal Pipe Line Limited (MPLL) field deployment exercise on 18 October 2019 which consisted of a simulated response to a tank fire at Tank #665 at the company’s East Montreal Terminal.  MPLL’s objectives for the exercise included verifying notification procedures, equipment deployment and fire protection functionality. The installation of a fire protection system was required by the CER under the Canada Labour Code so the exercise also served as a verification that it was installed and functioning.

The company provided CER Inspection Officers with a copy of the scenario for the exercise, an exercise plan and the fire safety and emergency measures plan to the CER the week of the exercise.  A draft Fire Safety and Emergency Measures Plan was provided on 16 October 2019 and a revised copy was provided on 17 October 2019. The semi-fixed fire suppression system was put in service in May 2019.
MPLL and the Montreal Fire Service (MFS) were the participants at the exercise as MPLL relies on the City of Montreal to provide the fire trucks to pump the water and mix in the foam concentrate at the site.  A pre-exercise briefing was delivered to the participants which included welcome, introductions, an overview of the scenario, objectives and rules of the exercise.  Personal protective equipment (PPE) requirements were reviewed with the participants.  Safety and mustering directions were provided in the event that there was a real emergency at the site.  All participants were asked to sign-in to the facility when they arrived.

Notification and Reporting
Internal notification procedures (starting with the discovery of the incident) and external notifications to the MFS and the CER were described by the company’s exercise controller during the pre-exercise briefing.  These notifications were focused on what would be required to initiate the tactical response to the fire on site.

Safety
A safety briefing was delivered by the exercise controller to the exercise participants, evaluators and observers during the pre-exercise briefing.  Required PPE was available and was used by all attendees.  The minimum PPE for entering the MPLL site is safety footwear, a hard hat and fire-resistant clothing. MPLL operational employees wore 4 head (i.e. CO, H2S, O2, and LEL) personal air monitors.  None of the participants left the immediate area where exercise activities were conducted.

Exercise-specific hazards such as working around hoses and water under high pressure were not discussed.  CER Inspection Officers observed that a couple of the nozzles placed on the ground by MFS were kicking back towards the fire trucks as the water discharge pressure was increased. While no participants were near the nozzles when this occurred, CER Inspection Officers are of the view that it would be beneficial for MPLL to discuss this hazard with the group of participants.
 
Although actual fire-fighting foam was not used in this exercise, CER Inspection Officers are of the view that a copy of the Safety Data Sheet for the foam that MPLL has stockpiled should be readily available to its fire emergency responders for reference.

Communications
Communications and division of labour between the MFS and MPLL were observed to work well: information was shared easily, challenges that developed were discussed and problems were resolved in an open and respectful manner.

Tactical Response
The steps for accessing the MPLL tank farm in the fire emergency response plan were followed by MFS, who brought three fire trucks to the exercise.  In addition to the Fire Chief, an engineer with the MFS and two instructors were in attendance. MPLL assigned two first responders to work with the MFS to set up and activate the foam/water application system. The MFS indicated that in a real event, they would respond with five trucks to ensure back-up capacity.

MPLL has a container next to the fire suppression system containing rigid and flexible hoses, foam eductors and pressure control valves (PCV) to be used during the response.  The copy of the emergency response plan developed for a response to a fire at the MPLL North Tank Field (the North Tank Field Fire Safety Plan and Emergency Measures document) was also posted within the container.  However, it was available in English only. While the bilingual ability of the first responders present didn’t pose any challenges, CER Inspection Officers are of the view that consideration should be given to having the materials available in French as well. MPLL will need to ensure that the procedures to be followed can be communicated and understood by all the necessary users.

The steps for the installation procedure for connecting the water and foam supplies to the fire pumper were listed in the North Tank Field Fire Safety Plan and Emergency Measures document however the installation procedures referenced connecting hoses from the foam barrels beside the foam collector to the eductor which were exercise-specific instructions. CER Inspection Officers note this will need to be updated to ensure an adequate installation procedure to be used in a real fire emergency, i.e. connecting the hose directly to the foam concentrate tank.
PCV’s were connected to the water supply piping as per the system design which calls for reducing the water pressure in order to obtain the correct foam/water ratio for optimum application. There are five pipes to access the water supply for the suppression system.  Three of the five were tested as part of this exercise.  It was observed that, in two instances, the connections between the PCV and the pipe were not sealed as the water was leaking around the PCV. MPLL personnel reported that this was not the case when the hydro-test of the system was conducted in April 2019.

Given the limitations with space for staging the trucks at the site of the fire suppression system, MPLL indicated that updates to the North Tank Field Fire Safety Plan and Emergency Measures document will be made which will inform first responders that the trucks are to be parked on an angle allowing for full set up of the water supply hoses, foam supply hoses and discharge nozzles.

The pumper trucks did not draw on the foam tank as part of this exercise in order to avoid wasting the foam and to avoid contamination of the soil within the bermed area of the tank.  Instead, the foam hoses were inserted into plastic barrels that were filled with water and detergent.

Post Exercise
At the conclusion of the exercise, all attendees gathered for an exercise debrief. The exercise controller indicated that there were some positive learnings from the activity, such as how to stage equipment at the site and the validation of the design of the fire suppression system.  He expressed thanks to the MFS for being available to participate in the exercise.

The creation of a formal exercise report was not discussed, however the company indicated that it would use the learnings to update the fire emergency response procedures for the North Tank Field.  The Fire Chief expressed his satisfaction with the exercise and the opportunity to work with the equipment at the site.

CER Inspection Officers are of the view that MPLL met the objectives for the exercise. CER Inspection Officers have noted some opportunities for improvement to MPLL’s Integrated Contingency Plan. Improvements include development of emergency response exercises and training, improvements to site-specific emergency response procedures for a tank fire emergency, and integration of these procedures within its emergency management program.

Compliance tool used: No compliance tool used

Observation 2 - Response Management

Date & time of visit: 2019-10-18 14:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Response Management
The Incident Command System was not explicitly used during this exercise as the exercise goal was a single tactical deployment to test the fire suppression system without examination of other aspects of response (logistics, finance, etc).  It appeared to CER Inspection Officers that the MFS was leading the fire response operations and that MPLL responders were assisting them in the response i.e. there was no MPLL participant designated as the Incident Commander (IC) for the simulated response.  The procedures created for the fire response indicated that an MPLL representative will be the Incident Commander.  In order to clarify response roles during an incident, CER Inspection Officers are of the view that MPLL should share its fire emergency response procedures with the MFS if the company hasn’t already done so. This would benefit MFS in understanding the IC role and incorporation of the role in future exercises. 

CER Inspection Officers note that there was no clear linkage between the MPLL Integrated Contingency Plan (ICP) and the North Tank Field Fire Safety Plan and Emergency Measures document. When MPLL updates the North Tank Field Fire Safety Plan and Emergency Measures document, CER Inspection Officers are of the view that linkages be made to the ICP and other relevant emergency response procedures used by the company to ensure consistency and integration.  In addition and as part of MPLL’s change management process, the ICP and MPLL’s emergency response training should include the North Tank Field fire response procedures if the company hasn’t already done so. 

The Integrated Contingency Plan identifies a tank fire with risk of boil-over as a possible worst-case scenario in the North Tank Field. Some MPLL personnel participating at the exercise appeared to be unfamiliar with boil-overs and how they are produced as well as preventative and protectives measures to take for boil-overs. CER Inspection Officer took the opportunity to explain boil-overs and sent reference documentation after the exercise.  MPLL personnel needs to be informed of the risks, hazards and the necessary controls related to tank fires, including for the potential escalation of a full surface tank fire to a boil-over event.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

The company shall provide written notice to the CER that the edits to the MPLL Integrated Contingency Plan (ICP) and the North Tank Field Fire Safety Plan and Emergency Measures document will be completed by 31 January 2020.  

Due date: 2019-12-02

Date closed: 2019-12-10
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