Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Emergency Management Inspection to verify company's liaison activities and continuing education program.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Introductory comments
Date & time of visit: 2019-03-08 15:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
The purpose of this inspection was to verify Enbridge’s compliance with section 33 to 35 of the Onshore Pipeline Regulations (OPR), related to Emergency Management (EM) liaison and continuing education programs in Quebec. It was conducted by two NEB Inspection Officers with three municipalities and Enbridge. Enbridge infrastructure is located on two of the three municipalities that the NEB Inspection Officers visited. The third municipality does not host an Enbridge pipeline on its territory, but its waters and shorelines could be impacted by a significant leak at the pipeline’s upstream location.- The first meeting was held on February 15th, 2019 in a municipal office in Montreal, including one Fire Service representative and one emergency management planner from la Direction de la sécurité civile de la Ville de Montréal and one EM Advisor of la Sécurité civile du Québec. During this meeting, la Direction de la Sécurité civile de la Ville de Montreal explained how Enbridge collaborated and exchanged information with them during last years, especially recently around emergency management and risk modelling.- The second meeting was held in a municipal office of Mirabel on March 4th, 2019, with two representatives of the Fire Service (Director and Deputy Director) and one EM Advisor of la Sécurité civile du Québec. Overall, Enbridge's outreach with Mirabel is appreciated because it has regular meetings with the municipality and the information provided was generally sufficient, including a recent (summer 2018) information session, discussions on local realities related to company emergency practices and procedures, and maps showing the location of the pipeline.- The third meeting was held in the Enbridge office in Montreal-Est on March 5th (am), 2019, with its employees involved in liaison and continuing education activities. The company was asked about its activities in Quebec in general, considering section 33 to 35 of the OPR. NEB Inspection Officers explained that this inspection also focusses on the cities of Montréal, Mirabel and Vaudreuil-Dorion.- The last and fourth meeting was held in the Fire Station municipal office of Vaudreuil-Dorion on March 5th (pm), with the municipal Fire Service representatives (Director and Deputy Director) and one EM Advisor of la Sécurité civile du Québec. According to the municipal office, liaison and continuing education activities have not occurred since 2015.
Compliance tool used: No compliance tool used
Observation 2 - Liaison
Date & time of visit: 2019-03-08 10:00
NEB Staff were informed that Enbridge has programs in place to liaise with agencies that may be involved in an emergency response and to inform persons who may be associated with an emergency response activity on the pipeline of the practices and procedures to be followed. The company' described their Public Awareness Program (PAP) which encompasses the company’s damage prevention (not a subject of this inspection, but mentioned so that there is no confusion with the public awareness program required by NEB’s Damage Prevention Regulations), liaison and continuing education programs, Liaison activities under this program include informing multiple parties about Enbridge’s operations and how to recognize and respond to emergencies involving an Enbridge pipeline. This outreach is conducted on a cyclical basis which varies depending on the group being engaged (landowner, emergency response agencies, railway offices, and third parties registered to conduct ground disturbance activities within a 16 km radius of the pipeline right-of-way).
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Enbridge is asked to inform NEB Staff in writing, by April 8th, 2019, of their intent to:- systematically inform Quebec municipalities that are located in the Enbridge's emergency response zones (including the ones that could be affected by river spill contamination), by April 30th, of the availability of Enbridge's lastly updated French version of its emergency response plan, and continue or start with them liaison and continuing education programs;- contact the Vaudreuil-Dorion Fire Service Director, by March 31st, in order to resume in the short and long term the liaison activities following the municipality's needs linked with those municipalities of the Vaudreuil-Soulanges area that could be affected by a river spill contamination as well, including an information meeting with these municipalities along the shore, by June 15th, 2019.- systematically and proactively contact the regional offices of the Sécurité civile du Québec, in order to discuss with them how they would like to be informed about Enbridge’s liaison and activities programs with the municipalities of their territory of jurisdiction.
Due date: 2019-04-08
Date closed: 2019-04-29 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 3 - Continuing education
Date & time of visit: 2019-03-08 11:00
Concerning the required continuing education related to section 35 of the OPR, NEB Inspection Officers were informed that Enbridge has a the goal of maintaining a comprehensive emergency responder continuing education program, which includes face-to-face meetings with organizations that may potentially be involved in responding to a pipeline emergency. Enbridge reports that during these annual meetings, Enbridge representatives provide emergency responders with the information they need to respond effectively in an emergency. The company confirmed that meetings held for continuing education purposes are not equivalent to emergency response training. They indicated that they recommend first responders to a free online emergency responder training portal (www.mypipelinetraining.com) that educates first responders on the techniques and skills necessary to address pipeline emergencies. The three courses offered within this training program include: Emergency personnel awareness (introduction), First responders operations (intermediate) and Hazardous materials technician (comprehensive). Enbridge tracks the agencies that sign up for the training program in order to better understand the knowledge level of its emergency responder stakeholders. Of note, this online training program is only available in English. Emergency response agencies looking to be trained in French are invited to directly contact Enbridge’s Public Awareness Team (at 1-877-640-8665 or by email at CdnPublicAwareness@enbridge.com) to request French training. The company told the NEB that this training follows the same curriculum as the online training and will be delivered in person. NEB Staff were also informed that the above-noted continuing education activities inform the company about where gaps may lie in the response capabilities of the local emergency responders resulting in further outreach, planned emergency response exercises or support through the company's Safe Communities grant program . In addition Enbridge completes supplemental stakeholder outreach as identified by each business unit and specific region. Decisions regarding supplemental activities are based on factors such as:
Although Enbridge’s continuing education program appears to be robust, NEB Inspection Officers note that more specific continuing education activities are needed, particularly with Vaudreuil-Dorion. Indeed, this municipality would like to be able to discuss alerting and mobilization systems, emergency response contacts, product safety data sheets, spill response training, response equipment, regional meetings and planning with municipalities along the shore of the Vaudreuil-Soulanges area. In general, Enbridge should also conduct continuing education activities with municipalities whose shore could be impacted by a spill even though the pipeline does not physically pass through their territory. Please refer to the Liaison Observation Information Request above, since it contains also continuing education elements to follow up with.
Observation 4 - Interoperability
Date & time of visit: 2019-03-08 12:00
Concerning the interoperability between Enbridge's Incident Command System and the multijurisdictional Quebec EM System, the NEB Inspection Officers observed that Enbridge organises different types of exercises in different locations in Quebec in partnership with municipalities that are also interested by these mutual operational activities. Moreover, since 2018 the company takes part of the Cadre de Référence Intervention Pipeline Committee, led by the Sécurité civile du Québec, and which is composed by municipal, provincial and federal EM reprsentatives in order to clarify roles and responsibilities between all stakeholders in cas of a pipeline emergency.Whereas these constructive activities are instrumental, in the short and long term, to continuously improve interoperability of emergency response plans and procedures between the company and the most important stakeholders from every jurisdiction in Quebec, NEB Inspection Officers observed that no full-scale exercise was integrated by Enbridge in their risk-based emergency exercise program for the emergency planning zones in Quebec. The company confirmed that, although they have organized a number of emergency response exercises in Quebec, that a full scale exercise has not been conducted. It was explained that the reason for this is that, in consideration of their Canada-wide risk based approach to exercising, they chose to plan and deliver several table top exercises in order to reach an increased number of municipalities in the province. Considering the concerted work on the Pipeline Response Framework (Cadre de Référence Intervention Pipeline - CRIP) and the alignment and integration of the Incident Command System (used by the oil majors in Quebec) with the multijurisdictional emergency management system applied in Quebec, the NEB considers response coordination to be a critical element. Consequently, Enbridge should demonstrate a progressive series of exercises (e.g. workshop to table top to full scale) geared towards refining response coordination in Quebec. In addition, municipalities expressed an interest in pipeline exercises, with varying degrees of complexity depending on their familiarity with the company.
Enbridge is asked to inform NEB Staff in writing, by April 8th, 2019, of their intent to integrate full-scale exercises in Quebec within the company's existing risk-based and progressive exercise program, starting at the latest in the 2020-2021 fiscal year and continuing after with a five-year cycle. This comprehensive exercise programming in Quebec should demonstrate the consideration of the emergency planning zones, multijurisdictional coordination plans and needs, diversity of scenarios and types of exercises and interest of first nations, municipal, provincial and federal stakeholders that could be legitimately involved on the Quebec territory.The next follow-up of the Quebec full-scale exercises integration within the current Enbridge's exercise program will be done by the NEB Inspection Officers during the 2019-2020 fiscal year.
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
