Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Minell Pipeline Limited
Operating company: Minell Pipeline Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Full-scale, external exercise involving multiple agencies. Minell is operated by Manitoba Hydro. Location: Russell, Manitoba. Scenario is a mock train derailment that results in a pipeline rupture and release of sweet natural gas. As a result of the mock event, Manitoba Hydro would require a complete shutdown of the Minell Pipeline to facilitate an inspection of the pipeline by external stakeholders.
Compliance tool(s) used:
Facilities:
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Exercise Planning and Conduct
Date & time of visit: 2017-03-28 09:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
The exercise scope along with specific objectives for the exercise and specific objectives for the participants were provided prior to the exercise. Rules of play and artificialities were discussed during the opening presentation by Manitoba Hydro. Canadian National Railway (CN) provided an opening presentation to discuss the company’s emergency response structure. This was beneficial as the exercise scenario involved both Manitoba Hydro and CN responding to the incident. As the exercise progressed injects were provided to participants to forward discussion among various agencies that would be impacted by the incident.
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
Date & time of visit: 2017-03-28 09:30
Notification and reporting were simulated for the exercise and not actually conducted. Notification procedures were followed as per Manitoba Hydro’s call-down procedures. A large print out was available to view. It was identified that some agencies needed to be updated to include either a 24/hr number or an after-hours number. Manitoba Emergency Measures Organization (EMO) noted that the on-call duty officer also had access to after-hour numbers for several agencies. EMO stated their contact lists were updated on more rigorous schedule than most agencies. As contact lists have their challenges in being the most up to date, the EMO duty officer can be called as a back-up should a number not work during an emergency.Incident classification was discussed and upgraded as the scenario unfolded.
Observation 3 - Safety
Date & time of visit: 2017-03-28 10:00
To ensure the appropriate hazard controls are in place, Manitoba Hydro would need to contact CN to verify what hazardous substances may be on the train. Manitoba Hydro responders would be conducting initial air monitoring at the site. For he purpose of the scenario, the trains cars that derailed were hauling grain. CN stated to never assume what the train cars are carrying until verified by CN staff.CN also noted, that St. Lazare has high rail traffic. Trains usually pass through town every 20 minutes. To ensure safety of the area, it is crucial to notify CN immediately to ensure rail traffic has stopped, and that another train is not approaching the scene.Several CN staff should be anticipated to arrive at site. It was noted during the exercise that CN’s responding staff would be keen to access the site to assess their own incident of the derailed train cars. CN staff could be wearing “blinders”, and hyper focused when approaching the site. It is important to quickly establish safety zones and a security perimeter, to ensure CN staff are made aware of the hazards and do not approach the site until safe to do so.
Observation 4 - Response Managament
Manitoba Hydro uses the Incident Command System (ICS) to manage responses. All participating agencies use ICS as well. Roles were assigned in the Emergency Operations Centre (EOC) that were consistent with ICS. Unified Command was used at site.The exercise was designed with injects that prompted discussion between participants. The use of the ICS Planning “P” that would include determining incident objectives and briefings was not part of the scope.Maps were available on the walls of the EOC of the incident site. Manitoba Hydro also demonstrated the quick accessibility of their Common Operating Picture (COP) software. This mapping software provides critical data of the area and information on critical infrastructures that may be impacted by the incident if gas were to be shut off.
Observation 5 - Communications
The town of St. Lazare where the incident occurred is known not to have adequate cell reception in the area due to the geography of the valley it is located in. Manitoba Hydro is aware of the limitations and prepared for the situation. Land lines, satellite radios, and two way radios were available to communicate from the field site to the EOC.A Liaison role was established to coordinate communication between agencies. As the scenario evolved, the town of St. Lazare would require an evacuation and aid from other municipalities for the response. This would activate the Manitoba Emergency Coordination Centre (MECC). As the impact of the incident expanded to surrounding municipalities, several municipal EOC would be activated. It was determined that a Manitoba Hydro sit rep would be best utilized in the MECC.External communications such as media releases were not part of scope.
Observation 6 - Response Tactics
As per the scenario, gas supply and electricty will need to be isolated from the town of St.Lazare. As a result further upstream municipalities will be impacted by the gas supply outage. The EOC Director has full authorization as per Manitoba Hydro's policy to shut down the pipeline.Manitoba Hydro’s First Responder demonstrated GIS technology (portable computer) that identified distances to the manual block valves and site of derailment and pipeline rupture. This included the pipeline-railway crossing and location of hydro lines. The process was discussed on how to isolate the rupture through operations of the manual block valves; or, if it became necessary, in cooperation with TransCanada PipeLines Limited via remotely through their system, specifically at the McAuley meter station. It was determined that the Site Command would to need to be at the top of the hill overlooking the incident site while maintaining a safe distance.A single representative of the St. Lazare Fire Department was on site. It was discussed the resources that may be available and the possible limitations. Many of the volunteers work at the Rocanville Potash Plant which in turn extends their response time.
Observation 7 - Post Exercise
Date & time of visit: 2017-03-28 13:30
Overall, the exercise was successful in achieving the exercise objectives.A debrief was conducted immediately after the exercise. All participants were able to provide feedback. The facilitator took notes during the debrief and clarified with participants what issues were raised and discussed what possible solutions might look like.During the debrief it was stated that TCPL and Manitoba Hydro would need to clarify if there was an Memorandum of Understanding (MOU) between the two companies as this will help with response readiness in remote areas. In the event that additional resources are required Saskatchewan RCMP can assist, however the limitation is that they have different radios. “Citizens on Patrol” are local volunteers that can also be called on to assist. It was also noted during the debrief that there is a mine close by with an airstrip. This can potentially be utilized to bring resources in or evacuate. First Responders indicated that more discussion is needed in regards to Incident Command and Unified Command.NEB’s staff observations are that participants were familiar with their roles and the needs of responding agencies during an emergency. NEB staff noted that the exercise (EOC and field component) conduct was a table-top exercise and not a full scale exercise. NEB staff recommend that equipment deployment and a fully activated EOC could be part of the scope during a future exercise. Manitoba Hydro did indicate that a previous exercise did have a fully activated EOC running.
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
