Compliance verification activity type: Field Inspection
Team:
Regulated company: Niagara Gas Transmission Limited
Operating company: Enbridge Gas Distribution Inc.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
The purpose of the inspection was to assess the implementation and the effectiveness of Niagara Gas Transmission Limited’s (NGTL) liaison and continuing education activities as required under sections 33 – 35 of the National Energy Board Onshore Pipeline Regulations. NEB staff met with the company and with various agencies in communities where areas where NGTL pipelines are operated (Akwesasne, Cornwall, Ottawa, Gatineau and St. Clair Township).
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: 2018-02-07 10:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
EGD is the operator of the NEB-regulated NGTL pipelines. The NGTL pipelines feed provincially-regulated distribution systems such as Gazifère and Union Gas. All of these companies are owned by Enbridge Energy Distribution Inc. The corporate relationship between these entities is relevant to this inspection as, depending on the location of the NGTL pipelines, the liaison and continuing education activities are primarily conducted by the provincially regulated company with EGD oversight.NEB Staff met with EGD staff and staff from various agencies that may be involved in an emergency response on NGTL pipelines. The information in subsequent observations summarizes the results of this compliance verification activity.
Compliance tool used: No compliance tool used
Observation 2 - Liaison
NEB Staff and EGD discussed how the company is meeting the requirements outlined in sections 33 and 34 of the OPR. EGD’s Emergency Program Office (EPO) liaises with all agencies that may be involved in emergency response on NEB pipelines on an ongoing basis. EGD stated that the EPO keeps up-to-date contact lists of all relevant liaison contacts in the Emergency Procedures Manual (EPM) and that these contacts are validated annually.EGD stated that all external agencies have access to the external EPM on their public website. Any feedback that is received from external partners is taken into consideration and incorporated into the EPM. EGD has also created an External Emergency Agency Procedures Information Manual in consultation with first responders. This manual is available through the Emergency Agency Information Portal, an internet portal which is password protected. The company accessed the portal during the meeting to demonstrate the type of information available to first responders. They also indicated that all external emergency response partners are invited to and are included in discussions related to the EPM content during annual exercises. EGD stated that the company liaises with first responders regularly during response to emergency calls made on its distribution system. In 2017 the company reported that they had responded to over 1 400 gas pipeline hits. None of these incidents occurred on NEB-regulated infrastructure. In addition, company-initiated continuing education activities (described in the following section) and emergency response exercises provide opportunities to further develop close working relationships between themselves and first responders. The company listed various committees and conferences that it is involved with to develop and maintain liaison with agencies that could be involved in an emergency response. Some examples given include the Independent Electricity System Operator Emergency Preparedness Task Force, Office of the Fire Marshall and Emergency Management Sector meeting and Ontario Association of Emergency Managers. The company indicated that it uses these networks to better understand new and emerging hazards in the area of emergency management and to identify additional liaison opportunities.NEB staff also discussed EGD’s liaison activities with relevant municipal and Indigenous emergency management agencies.The NEB heard that first responders in Ottawa and Gatineau were pleased with the integration and support that the company provided their municipal EOCs during the flood emergency of 2017. The NEB also heard that liaison activities related to emergency response with the City of Gatineau are conducted primarily by the provincially regulated distribution company, Gazifère. The City of Gatineau reported having an excellent relationship with the company.NEB staff heard that relationships between the local EGD representative and communities influenced the degree to which the communities felt engaged and informed. In most instances the relationship is reported to be excellent however Akwasasne did express some concern regarding the amount of EM-specific engagement, including a lack of hard copies of the EPM. EGD outlined its engagement efforts with the Akwasasne and committed to send them hard copies of their EPM and to follow up with them regarding EM engagement-specific concerns.All municipal first responders that the NEB spoke with indicated that they were adequately prepared to respond to a natural gas emergency.
Observation 3 - Continuing Education
EGD described its continuing education program to NEB staff. Continuing education activities target first responders, landowners residing within 200m of the pipeline and members of the public. The type of education offered varies based on the needs of the target audience and their expected role, if any, in the event of a natural gas emergency.EGD described its first responder training program to NEB Staff. EGD offers a three hour course, Natural Gas Awareness Training (NGAT), which was developed by the Canadian Gas Association (CGA) in consultation with natural gas delivery companies and fire departments across Canada. This course is delivered, on request, to all fire departments and emergency responders in their franchise area and is promoted through municipal outreach programs and engagement activities. They reported that they train approximately 230 fire fighters a year. The company will be trialing a new training approach in 2018. EGD has worked with the Ontario Association of Fire Chiefs to develop a one day train-the-trainer course which will certify individuals to deliver the NGAT course. The goal of this is to reach more first responders via external trainers.The company also described a mock village that it has on site that is open to first responders for additional hands-on training to practice response to natural gas leaks in a controlled environment.Akwesasne reported that it had not received training from EGD on Natural Gas Awareness and that they would be interested in such training as it would be complementary to hazardous waste operations and technical training that they had received from other agencies. It stated that it is important to have the training to know what the potential impacts are, and to communicate this to members of their community. The company committed to offer the CGA training materials to Akwesasne. In Gatineau, the NEB heard that although pipeline safety training has been provided in the official language of choice, the supporting documentation was not always translated. In follow-up conversations with the NEB, EGD described its capacity to work in both official languages and it committed to engage Gatineau Fire further on language-related concerns and to send them a copy of the French version of the CGA training materials. The company reported that continuing education materials are provided to landowners within 200m of the pipeline on an annual basis. This public awareness program package is sent through direct mail. A sample of their 2018 materials was provided to NEB staff. The package included a map of the pipeline route, safety information and a number to call in the event of a suspected natural gas emergency. Considering that some landowners reside adjacent to the NGTL pipelines in the Gatineau area, the NEB questioned whether continuing education materials were available in the official language of choice. The company noted that none of the landowners have raised concerns regarding the language used in the mailout. EGD also conducts outreach presentations and it referenced their “Smelfie” campaign which has directly engaged about 300 000 people to date. The goal of this campaign is to demonstrate what odorized natural gas smells like, so that people are able to recognize when there may be a gas leak nearby.
Observation 4 - Interoperability between NGTL and those who may be involved in an emergency
NEB Staff and EGD discussed how the company’s preparedness activities discussed above are designed to ensure interoperability between company plans and both municipal and first responder emergency response plans. EGD said that it uses the Incident Command System (ICS) and that it would align with partner agencies in a unified command structure, when necessary. EGD emphasized that responses to actual incidents and simulated responses during exercises provide an excellent opportunity to continually test and improve interoperability between itself and other members of the response community.EGD stated that in 2017, it joined the City of Ottawa, Durham Region, and the Town of Carleton Place in their municipal exercises. It also participated in a mercaptan leak exercise with another third party. EGD participation in these exercises is based on availability and resources of external partners and where they are aligned with EGD's hazards and risks.As a result of the flood emergency in Ontario and Quebec in 2017, EGD stated that it learned that it is important to staff a Liaison position in the municipal Emergency Operations Centre. NEB heard from the municipalities that they appreciated the company’s participation in the flood response, and have included a regular seat for them in their municipal EOC (OMSC in Québec).In response to a question from the NEB seeking clarification on the relationship between Gazifère, EGD and NGTL regarding emergency management and response, EGD confirmed that the emergency response training and procedures are equivalent amongst the three companies, which are all owned by Enbridge Energy Distribution Inc. EGD states that the emergency response to a natural gas emergency is conducted in the same way, regardless of location (Ontario or Quebec) or type of pipeline (transmission or distribution).
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
