Compliance Verification Activity Report: CV2122-224 - Kinder Morgan Cochin ULC, PKM Cochin ULC

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-224
Start date: 2021-11-04
End date: 2021-11-04

Team:

Regulated company: Kinder Morgan Cochin ULC, PKM Cochin ULC

Operating company: Pembina Pipeline Corporation

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

To verify response capabilities during PKM Cochin's Functional exercise held in Wainright, AB on 4 November 2021. The exercise scope, objectives and external participation will be determined closer to the exercise date. The company advised that the exercise may be virtual depending on COVID-19 restrictions. The last exercise was evaluated by CER staff in 2016/17 (CV1617-447).

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Emergency Response Exercise Evaluation - PKM Cochin ULC

Discipline: Emergency Management

Categories:

Facility:

Observations:

Exercise Overview, Planning, and Design – Facilitation and Control

On 04 November 2021, PKM Cochin ULC (PKM or the Company) conducted a functional exercise at the Vegreville Pump Station, in Vegreville, AB. In attendance at the exercise were Company personnel, external consultants to facilitate the exercise and Canadian Energy Regulator (CER) staff. No external stakeholders or responders participated in the exercise.

The exercise focused on the virtual coordination at the Incident Command Post (ICP) with simulated inputs from the Corporate Emergency Operations Centre (CEOC), the Field and Pembina’s Sherwood Park Control Centre. The main objective, as explained to participants, was to test the new mobile command post and its supporting equipment. Company personnel were asked to consider what might be needed in a response, for example, how to set up the desks and computers and office space more effectively.  The exercise began with sign in and introductions, then the facilitator reviewed the rules of play, safety and COVID-19 measures/mitigations, PPE, potential hazards and a review of the exercise goals, objectives, and the scenario.

As stated by the Company, the goals of the exercise include:
 

 
CER staff are of the view that these goals were realistic for the scenario and observed completion of and/or adequate progress of each one. The scenario was designed in consideration of the potential hazards and risks posed to PKMs operations. In this case, a landowner preventing company access to the release site was identified as the hazard to implementing an immediate response. This scenario also allowed for simulation of a prolonged response to a diluent spill that would usually be absorbed to the atmosphere in 6 to 8 hours. 
Unified Command (UC) was established with the CER. CER staff noted that this was not discussed ahead of time, however, when asked, the Company immediately engaged attending CER staff in UC and demonstrated knowledge of how to work within that structure.

Notification and Reporting

The Company activated an emergency response and determined the incident to be a level II emergency in accordance with its ERP. There was no requirement to notify the CER as the exercise scenario was simulating the second day of the response and as such, notifications would have already been made. However, the Company did provide a courtesy notification to the CER.

Safety

CER staff observed that Company personnel identified the product as Texas condensate used for diluent in oil sands bitumen shipment and were aware of the specific product characteristics. A safety briefing was conducted with exercise participants. CER staff did not observe if considerations for decontamination were discussed.

Response Management

CER staff observed that the ICS was followed, the Company responded in accordance with its ERP, and participants adapted to the changing scenario as required. Throughout the exercise company participants made use of the tools available to them to work through several “Planning P” - (a graphic depiction of the operational planning cycle) - meetings, such as the EPM and role specific guides.

CER staff observed that the possibility of an extended response was considered concurrently from the start of the exercise and planning conducted accordingly – such as relieving roadblock crews and establishing a night shift. A meeting schedule was established and posted on the wall in the response trailer and in the MS Teams platform. Maps from the ERP were used and displayed on the television screen. An operational period was established, and an incident status board was maintained throughout the exercise.

A CEOC was established, primarily for the Finance Section Chief role, however, air modelling, product migration and recovery were also discussed during CEOC updates. 

Response Communications Technology & External Communications

Cell phones and computers were identified as the primary communication methods for the exercise. This equipment was appropriate for the requirements of the exercise. However, CER staff observed that there were some issues with hotspot connectivity within the mobile command unit, likely due to the structure (a large steel box) as cell reception in the area was strong. Company personnel identified that in addition to the hotspot units, a mobile cell reception tower should be purchased for use with the mobile command units. CER staff agree, as ensuring effective and consistent communications methods is a regulatory requirement and critical during a response.
 
Media interest was noted and CER staff observed that participants were aware of the crisis communications plan and the developed holding statement.
 
Tactical and Strategic Response

Participants were familiar with their roles and responsibilities and demonstrated through discussion, an understanding of the roles of emergency services and other personnel – such as Alberta Highways. CER staff observed discussion of appropriate strategies and tactics for the scenario including identification of key resources and spill response equipment. Discussions included appropriate air monitoring, establishing staging areas, hazard monitoring, site access, security, roadblocks, and road closures. For the air monitoring, participants discussed that single source air monitoring would not be sufficient – rather an appropriate amount of air monitoring towers to cover the entire area and contingency area should be deployed.
 
Public Protection

CER staff observed that public protection and mitigation measures were discussed and appropriate to the scenario.

Environment Considerations

CER staff observed that environment considerations were discussed, and appropriate mitigation measures considered, such as fencing the impacted area for overnight prevention of animals encountering product and potential bird hazing requirements.

Post Exercise

A debrief was held at the end of the exercise. Exercise participants identified what worked well and what needed improvement, and these were captured for future exercises and continuous improvement.  An After-Action Review and Debrief will be completed following the exercise and all identified action items will be documented in the exercise report. All action items will be entered into PKM’s Emergency Management Action Tracker and assigned a completion timeline. Timelines will be established based on the complexity of the action required.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

PKM Cochin ULC. is requested to file an after action report.
Follow instructions in the Documents section to upload and submit the AAR by 23 February 2022. The AAR should describe:

The AAR should also include a corrective action plan, identifying corrective actions, milestones, status, the responsible party or agency, and the expected completion date.

Due date: 2022-02-23

Date closed: 2022-03-03
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