ARCHIVED – Many Islands Pipe Lines (Canada) Limited: Hazard and Risk Assessment as related to Emergency Management – OF-Surv-OpAud-Ml82-2017-2018 01

AP01

1.1 Policy and Commitment Statement

OPR s. 32 (1): A company shall develop, implement and maintain an emergency management program that anticipates, prevents, manages and mitigates conditions during an emergency that could adversely affect property, the environment or the safety of workers or the public.

Status: No issues of non-compliance identified.

OPR s. 32 (1.1): The company shall develop an emergency procedures manual, review it regularly and update it as required.

Status: No issues of non-compliance identified.

AP02

1.1 Policy and Commitment Statement

OPR s. 6.3 (1): The company shall establish documented policies and goals for meeting its obligations under section 6, including (b) goals for the prevention of ruptures, liquid and gas releases, fatalities and injuries and for the response to incidents and emergency situations.

Status: No issues of non-compliance identified.

AP03

3.3
Management of Change (MOC)

OPR s. 6.5 (1)(i): establish and implement a process for identifying and managing any change that could affect safety, security or the protection of the environment, including any new hazard or risk, any change in a design, specification, standard or procedure and any change in the company’s organizational structure or the legal requirements applicable to the company;

Status: No issues of non-compliance identified.

AP04

3.4 Training and Competence

OPR s. 6.5 (1)(j): establish and implement a process for developing competency requirements and training programs that provide employees and other persons working with or on behalf of the company with the training that will enable them to perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment;

Status: No issues of non-compliance identified.

AP05

3.6
Documentation and Doc Control

OPR s. 6.5 (1)(o): establish and implement a process for preparing, reviewing, revising and controlling those documents, including a process for obtaining approval of the documents by the appropriate authority;

• Although the company demonstrated that some of its emergency management documentation was reviewed, revised and maintained, it did not demonstrate that it was subject to the documented management system level document control process that meets the requirements of OPR s. 6.5 (1)(o) (Refer to Appendix I Protocol Item AP-05);

Status: Non-Compliant

AP06

4.1 Inspection Measurement and Monitoring

OPR s. 6.5(1)(u): establish and implement a process for inspecting and monitoring the company’s activities and facilities to evaluate the adequacy and effectiveness of the programs referred to in section 55 and for taking corrective and preventive actions if deficiencies are identified;

Status: No issues of non-compliance identified.

AP07

2.1 Hazard ID

OPR s. 6.5 (1)(c): establish and implement a process for identifying and analyzing all hazards and potential hazards;

• Although MIPL(C)L conducts various activities to identify hazards, the NEB did not see an explicit, systematic management system process to identify and analyze the hazards and potential hazards applicable to the EM Program. Further, the NEB did not see evidence of an explicit systematic documented process detailing how outputs of the hazard identification and analysis activities were integrated with or used in the development and maintenance of the EM Program and procedures. (Refer to Appendix I Protocol Item AP-07)

Status: Non-Compliant

AP08

2.1 Hazard ID

OPR s. 6.5 (1)(d): establish and maintain an inventory of the identified hazards and potential hazards;

• MIPL(C)L provided an all-hazard list for review. Originally developed to plan for emergency events at the provincial level, this list and does not reflect the hazards or potential hazards specifically related to the MIPL(C)L facilities. Therefore, it did not meet the requirements of the OPR s. 6.5 (1)(d).

Status: Non-Compliant

AP09
2.1 Hazard ID

OPR s. 6.5 (1)(e): establish and implement a process for evaluating and managing the risks associated with the identified hazards, including the risks related to normal and abnormal operating conditions;

• Although the company has developed processes to guide in completing risk assessments, the company did not demonstrate that it has a process for evaluating and managing the risks associated with identified hazards, including the risks related to normal and abnormal operating conditions as it relates to the MIPL(C)L EM Program. Further, the company did not demonstrate how outputs of the process for evaluating and managing the risks associated with the identified hazards are (or would be) integrated, or used, in the development and maintenance of the EM Program.

Status: Non-Compliant

AP10

2.1 Hazard ID

OPR s. 6.5(1)(f): establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards and the risks and for communicating those controls to anyone who is exposed to the risks;

• The company did not demonstrate that it has established and implemented a documented, explicit methodology to be followed for the development of controls and for communicating those controls within the EM Program.

Status: Non-Compliant

AP11

3.2
Operational Control-Upset or Abnormal Operating Conditions

OPR s. 6.5 (1)(t): establish and implement a process for developing contingency plans for abnormal events that may occur during construction, operation, maintenance, abandonment or emergency situations;

• Although MIPL(C) L demonstrated that it has included contingency planning within its response procedures, it has not provided a documented process for contingency planning for abnormal events that may occur during emergency situations.

Status: Non-Compliant

AP12

4.1 Inspection Measurement and Monitoring

CSA Z662-15 – clause 10.5.2.1 – CSA Z662-15 – clause 10.5.2.4

Status: No issues of non-compliance identified.

Topic: National Energy Board Onshore Pipeline Regulations: Section 32 (1)

NOTE: Given the scope of this audit, the elements and regulatory requirements examined will be related to the hazards and potential hazards that would initiate emergency or contingency responses.

Regulatory Requirement: OPR s. 32 (1): A company shall develop, implement and maintain an emergency management program that anticipates, prevents, manages and mitigates conditions during an emergency that could adversely affect property, the environment or the safety of workers or the public

32 (1.1): The company shall develop an emergency procedures manual, review it regularly and update it as required.

Can the company demonstrate that it has developed, implemented, and maintains an emergency management program that anticipates, prevents, manages and mitigates conditions during an emergency?

Can the company demonstrate that it has developed an emergency procedures manual that anticipates, prevents, manages and mitigates conditions during an emergency?

Can the company demonstrate that it has reviewed the emergency procedures manuals on a regular basis and update the manuals as required?

No issues of non-compliance identified.

Unified Management System

At the time of the audit, MIPL(C)L was implementing a Unified Management System (UMS) which is outlined in the Unified Management System framework document. This document states that the purpose of the UMS includes integrating the company’s operational activities and technical systems with its management of human and financial resources to enable the company to meet its obligations. Further, it states that the UMS ensures coordination between its programs including its emergency management program, integrity management program, pipeline control system, safety management program, security management program, environmental protection program and damage prevention program. The UMS has been structured based on current operations, systems, processes and procedures in place, and establishes the processes used by the company for the safety and security of the public and the company’s employees, the safety and security of the pipeline, and the protection of property and the environment. The UMS drives operational controls as a means to ensure that the obligations of the UMS are met. This is done by requiring the establishment, implementation and maintenance of appropriate procedures and operating criteria, including those required to address abnormal operating conditions.

The Asset Management System outlined within UMS, is a coordinated set of programs that addresses the company's asset management responsibilities in a manner that supports the achievement of the objectives of the UMS. The Asset Management System is comprised of 16 programs, one of which is the Corporate Emergency Management Program.

Corporate Emergency Management Program (CEMP)

MIPL(C)L is governed by a Corporate Emergency Management Program (CEMP) which also applies to all emergency planning and response activities within SaskEnergy. According to the CEMP Program Manual, the “The CEMP provides specific direction to functional areas of the company which are:

• Engineering;
• Distribution Operations;
• Transmission Operations; and
• Pipeline Control and Planning.”

The CEMP incorporates procedures that are to be used as controls to mitigate and respond to threats as listed within the CEMP document. The CEMP methodology separates “threats” into pre-event (mitigation and preparedness) and post-event (response and recovery). Preparedness includes; forecasting the types of emergencies that could occur and the people, equipment, organization and training that would be required to respond effectively.

Emergency Procedures Manual

The Emergency Response Manual that applies to MIPL(C)L includes details of each facility operated by MIPL(C)L, schematics, guidelines for response and reporting and an emergency contact list for each pipeline. The manual contains procedures to be followed for events such as responding to chemical spills, odour releases or spills, and civil disturbances.

In accordance with the annual review process, Section 6 of the manual lists the reviews and revisions of the manual since 2015. The Board notes that these updates have occurred in accordance with the requirements of OPRs. 32 (1.1) which states: “The company shall develop an emergency procedures manual, review it regularly and update it as required.”

Based on the review conducted and considering the scope of this audit, the Board did not identify any issues of non-compliance in relation the above requirements.

Although no issues of non-compliance are noted with OPR s.32 (1.1), section AP05 of this report reviews the lack of a documented management system level document control process as required by s. 6.5 (1) (o) being applied to the Emergency Response Manual.

Topic: Management System Sub Element 2.3 – Goals, Objectives and Targets

NOTE: Given the scope of this audit, the elements and regulatory requirements examined will be related to the hazards and potential hazards that would initiate emergency or contingency responses.

Regulatory Requirement: OPR s. 6.3 (1): The company shall establish documented policies and goals for meeting its obligations under section 6, including (b) goals for the prevention of ruptures, liquid and gas releases, fatalities and injuries and for the response to incidents and emergency situations.

Can the company demonstrate that it has developed goals related to its hazards and risks for its Emergency Management Manuals, contingency plans and Emergency Management exercises?

No issues of non-compliance identified.

MIPL(C)L adheres to an Emergency Management Policy which states that the company shall, through its emergency procedures, respond to all emergencies involving its facilities and service to its customers. The policy states that procedures contained within the company (Emergency Response) manual will be followed and applied as necessary, depending on the nature of the incident.

According to the policy for Internal Reporting of Hazards, Incident and Near Misses, workers are encouraged to identify hazards, incidents and near misses at their work site. The policy also includes a commitment to protect employees from any form of discipline related to the identification of hazards, incidents and near-misses in the work place.

The EM Program goals are described in the “Set Annual Program/Plan Goals, Objectives, and Targets (GOTs)” document which outlines expectations and requirements needed to manage the activities that align with the corporate direction and priorities. This document states one of its purposes as, “to establish goals for the prevention of ruptures, liquid and gas releases, fatalities and injuries and for the response to incidents and emergency situations”.

MIPL(C)L provided the 2017 CEMP Goals and Objectives document, which describes seven objectives. During the audit, MIPL(C)L stated that these objectives and targets are developed by the Executive Steering Committee and are reviewed quarterly to monitor performance in meeting established targets.

In addition, the SaskEnergy/TransGas Pipeline Integrity Management Program states that, “the overall goal of pipeline integrity is to ensure the safety of the public and environment.” The Integrity Management Policy statement specifically includes goals for the prevention of ruptures, releases, fatalities and injuries. Further, the Integrity Management Program document includes a statement that Corporately, the vision for pipeline incidents is; zero ruptures, zero fatalities, and zero injuries.

As part of the CEMP, SaskEnergy/TransGas Engineering, has developed a functional level plan for the programs under the CEMP umbrella. This plan includes a listing and status update for EM Program objectives and targets for 2016, and plans for 2017 and for the next four years (2018 through to 2021). The plan directs that performance measures with objectives for other plans and controls will be reported to the CEMP Steering Committee and the Executive.

SaskEnergy Operations has developed response time expectations for the federally regulated transmission system, which are aligned with availability of staff to respond to emergencies. MIPL(C)L indicated that for locations on its transmission system (outside of manned stations), it is expected that personnel will respond to the locations within 1.5 hours, more than 95% of the time. Response time expectations are also outlined for manned locations.

Based on the review conducted and considering the scope of this audit, the Board did not identify any issues of non-compliance in relation to this requirement.

Topic: Management System Sub Element 3.3 – Management of Change (MOC)

Regulatory Requirement: OPR s. 6.5 (1)(i): establish and implement a process for identifying and managing any change that could affect safety, security or the protection of the environment, including any new hazard or risk, any change in a design, specification, standard or procedure and any change in the company’s organizational structure or the legal requirements applicable to the company;

Can the company demonstrate that it has established and implemented a process for identifying and managing any change that could affect safety, security or the protection of the environment, including any new hazard or risk, as it relates to the ongoing development of Emergency Management Manuals, Contingency Plans and Emergency Management Exercises?

No issues of non-compliance identified.

As part of the UMS implementation, MIPL(C)L adheres to a MOC procedure and a MOC process document, each of which outline expectations and requirements to manage the critical activities necessary to minimize the risks associated with permanent or temporary changes. The process as stated is to be used to, “identify and manage changes that could affect people, property, the pipeline system and the environment. This includes any new hazard or risk, any change in design, specification, standard or procedure”.

As outlined in the Process Safety Management Program, the Program plans and manages the MOC process for process safety at the operational and facility change level.

The MIPL(C)L Emergency Response Manual, specifies that, “ any errors, omissions or requests for revisions will be documented through the Management of Change (MOC) process”. During the audit, MIPL(C)L provided records to demonstrate the MOC process was recently applied to revise the MIPL(C)L Emergency Response Manual as a result of a disposition of an asset.

Based on the review conducted and considering the scope of this audit, the Board did not identify any issues of non-compliance in relation to this requirement.

Topic: Management System Sub Element 3.4 – Training, Competence and Evaluation

Regulatory Requirement: OPR s. 6.5 (1)(j): establish and implement a process for developing competency requirements and training programs that provide employees and other persons working with or on behalf of the company with the training that will enable them to perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment;

Can the company demonstrate that it has a process for developing competency requirements and training programs as required for, and within, the Emergency Management Program?

No issues of non-compliance identified.

SaskEnergy/TransGas has developed a Competency Assessment Plan (CAP) which is controlled by the training group within the Human Resources department. This plan provides a standardized approach to ensure workers are qualified and competent to perform activities or tasks on the company’s pipeline systems including the MIPL(C)L facilities. This CAP includes details to what needs to be completed in developing qualification plans and outlines responsibilities to be considered to ensure proper training is administered and that an evaluation (and re-evaluation) of knowledge and an evaluation of competency for activities or tasks is completed. Specific evaluation methods are provided to evaluate workers performing a specific task or activity. These methods include written and oral examinations, and observation/evaluation of performance; on the job, during on the job training, and during simulations. CAPs for various operational tasks related to emergency response including:

• CAP 55 – responding to an emergency on the system;
• CAP 55A – a Skills Checklist for responding to an emergency (Distribution); and
• CAP 55C – provide the evaluation of worker knowledge in responding to emergencies including response to; explosion, fire, odour/fume/CO calls, and hazardous material spills.

During the audit, MIPL(C)L stated that emergency response exercises are considered to be effective tools for training staff for response and to evaluate their competency in responding to emergency events. Over the 2016-2017 year, 30 tabletop exercises completed throughout the company, two of which were specific to the transportation system. In addition, two of the three simulation exercises were specific to MIPL(C)L. It was also noted that a mock exercise is scheduled to be completed for MIPL(C)L in 2018.

MIPL(C)L demonstrated through documentation provided that it has developed an Operations Training Matrix. This matrix identifies required training courses for positions within the Operations team. Included within these courses is the Online Emergency Response 101 Course which is mandatory for most positions. Incident Command System (ICS) 100 and ICS 200 are also included within the training matrix; however, these courses are only considered mandatory for selected positions. Based on documentation reviewed, the NEB noted that:

• 422 employees completed the Emergency Response 101 Course;
• 130 employees completed ICS 100 training;
• 72 were trained in ICS 200; and
• Percent of required training completed exceeded 97%.

The NEB was advised during interviews that the Human Resources department has recently included emergency management training within its Learning Management System. This change will represent an improvement to existing practice as going forward. The system will monitor and report on training requirements and certification expiries. According to MIPL(C)L, contract personnel do not have responsibilities related emergency response on behalf of the company.

Based on the review conducted and considering the scope of this audit, the Board did not identify any issues of non-compliance in relation to this requirement.

Topic: Management System Sub Element 3.6 – Documentation and Document Control

Regulatory Requirement:  OPR s. 6.5(1)(o): establish and implement a process for preparing, reviewing, revising and controlling those documents, including a process for obtaining approval of the documents by the appropriate authority;

Can the company demonstrate that it has established and implemented a process for preparing, reviewing and controlling documents and that it uses the process for the Emergency Management Manuals and Contingency Plans?

Non-Compliant

During interviews and document review, MIPL(C)L indicated that it adheres to the corporate UMS Documentation Management Procedure (DMP). First released in 2016, the DMP provides guidance on the preparation and maintenance of UMS related documentation and includes requirements of UMS documents to include identification of document owner, reviewer, and record of annual review(s) and updates. Direction includes guidelines for; creating, revising, reviewing, approving, and deleting UMS documents. According to the document, this procedure applies to Program, Plan and System owners and is to be applied to UMS controlled documents. During the audit, the NEB reviewed several management system level process documents that appeared to be subject to an overarching document management process in that they followed a prescribed style and demonstrated consistent review, revision and approval practices.

Review of the MIPL(C)L Emergency Response Manual identified that it is version controlled on the CEMP SharePoint site – MIPL(C) L Emergency Response. Distribution of the document is primarily electronic through the SharePoint site where access to versions is based on site permissions. Additionally, it was identified that four (4) hard copies are provided to select recipients, including the NEB, and printouts are considered uncontrolled.

Over the course of the audit, MIPL(C)L demonstrated that its Corporate Emergency Management Manual was subject to review, revision and updating when changes were required. The NEB noted, however, that the current review, approval and updating process is unique to the Emergency Manual and therefore MIPL(C)L did not demonstrate this document is subject to the overarching management system level DMP document control and approval process.

The NEB reviewed other EM Program documentation to verify its conformance to the DMP and noted the following inconsistencies:

• The CEMP Manual is dated “2017”, has the SaskEnergy / TransGas watermark, but revision history and approval tracking are not consistent with other management system documentation requirements.
• The CEMP Functional Level Engineering Plan is dated “2017-2-15,” has the SaskEnergy / TransGas watermark, however the revision history and approval tracking are not consistent with other management system documentation requirements.
• The MIPL(C)L Emergency Response Manual is dated “September 2017”, has no watermark, a revision history and approval signature that are not consistent with other management system documentation requirements.

Given the inconsistencies noted between the EM documentation and the other management system documentation that was provided, the Board determined that MIPL(C)L has not consistently implemented a process for preparing, reviewing, revising and controlling those documents, including a process for obtaining approval of the documents by the appropriate authority for its EM Program documentation. Therefore, MIPL(C)L is in non-compliance with OPR s. 6.5 (1)(o) as it relates to its EM Program documentation. The Board requires that a CAPA Plan be developed to address this non-compliance.

Topic: Management System Sub Element 4.1 – 1 Inspection, Measurement and Monitoring

Regulatory Requirement: OPR s. 6.5(1)(u): establish and implement a process for inspecting and monitoring the company’s activities and facilities to evaluate the adequacy and effectiveness of the programs referred to in section 55 and for taking corrective and preventive actions if deficiencies are identified;

Can the company demonstrate that it has established and implemented a process for inspecting and monitoring the company’s activities to evaluate the adequacy and effectiveness of the Emergency Management Program and for taking corrective and preventive actions if deficiencies are identified?

No issues of non-compliance identified.

During the audit, MIPL(C)L discussed several activities it conducts to monitor and evaluate the effectiveness of its EM Program. These activities include audits, emergency exercises and documented de-briefs for emergency events that required ICS.

SaskEnergy/TransGas Audit Services is responsible for the internal audits of company processes and programs on a three-year basis. Audit Services completed an audit of the EM Program in 2016 to determine if the CEMP meets the requirements of the OPR. The final report was released 6 February 2017 containing one observation for correction. The issue was assigned to a Management Sponsor to develop an appropriate action plan to address identified gaps, with a due date of 31 March 2018. In this case, the action required updating emergency impact zones and lists for MIPL(C)L pipelines. According to MIPL(C)L, this action has been addressed.

MIPL(C)L also evaluates and monitors the adequacy of its EM Program by using debriefs to capture lessons learned following events that required the activation of ICS.

It was noted during the audit that SaskEnergy/TransGas runs various emergency management exercises throughout its system on a regular basis. These exercises include practices for gathering direct and indirect participant feedback that is incorporated into the update of EM procedures, EM training and when evaluating emergency response equipment. Emergency response exercises are documented and may include debriefings to identify deficiencies or possible improvements. The Board noted that the 2012 Mock Exercise identified several recommendations for consideration by EM Program management.

Based on the review conducted and considering the scope of this audit, the Board did not identify any issues of non-compliance in relation to this requirement.

Topic: Management System Sub Element 2.1 Hazards Identification, Risk Assessment and Control

Regulatory Requirement: OPR s. 6.5 (1)(c): establish and implement a process for identifying and analyzing all hazards and potential hazards;

Can the company demonstrate a process for identifying and analyzing all hazards and potential hazards

Non-Compliant.

SaskEnergy/TransGas provided the Hazard Identification Process for review. This process is utilized throughout the organization for identifying hazards in the workplace and for operations. Once hazards are identified, employees use the REO (Report Everything Online) System to capture hazards, near misses and incidents. Within REO, each hazard is classified as personal, public, or as a process safety hazard. Hazards are then risk ranked, and corrective actions applied if risk cannot be managed immediately. Similar procedures are followed for near misses and incidents.

The Policy for Internal Reporting of Hazards, Incident and Near Misses includes an expectation of workers to identify hazards, incidents and near misses. The Policy also states that “Management will review all documented reports and take appropriate action relative to the seriousness of the risk identified.” Further, all employees are encouraged to be actively observing their work places and work tasks to identify possible risks and to report these within the REO system.

Hazards related to health and safety are also identified during:

• HAZOPs;
• tailgate meetings;
• Pre-job Meeting;
• Safe Work Permit process; and
• Field Level Risk Assessment.

The Field Level Risk Assessment is designed for employees to identify potential hazards that may exist for the task and assign the corresponding control to manage the hazards.

Although the company demonstrated that it has implemented several hazard identification activities, it did not provide documentation to demonstrate how the hazards or potential hazards identified through the mechanisms are to be captured in REO, captured in a hazard inventory or analyzed for their application to the EM Program. For example, as part of the UMS, the Process Safety Management (PSM) Gap Registry and Management process outlines the methodology to identify hazards and perform standardized risk assessments, and provides corrective and preventive action items. The inputs of this process originate from monthly meetings with subject matter experts reviewing Process Safety incidents in REO, and long term action items from Root Cause analysis reports/incident investigations.

Additionally, hazards are identified within the All Hazards Risk Assessment Process which describes the process of reviewing the Risk and Hazards inventory as well as defining the relevance and impact of those risks and hazards. In reviewing this document, the All Hazards Risk Assessment Process does not include a methodology or process to analyze hazards and potential hazards.

As described above, MIPL(C)L conducts various hazard identification activities, especially with respect to worker safety. However, the company did not demonstrate that it has an explicit, systematic process to identify and analyze hazards and potential hazards related to the EM Program. Further, the company did not provide an explicit systematic documented process describing how outputs of the hazard identification various activities were integrated into or analyzed in the development and maintenance of the EM Program.

As a result of the assessment, the Board has determined that MIPL(C)L is in non-compliance with OPR s.6.5 (1)(c). The Board requires that a CAPA Plan be developed to address this non-compliance.

Topic: Management System Sub Element 2.1 Hazards Identification, Risk Assessment and Control

Regulatory Requirement: OPR s. 6.5 (1)(d): establish and maintain an inventory of the identified hazards and potential hazards;

Does the company have and maintain an inventory of the identified hazards and potential hazards

Non-Compliant.

At the time of the audit, MIPL(C)L provided an All Hazards List for review as its inventory of hazards and potential hazards. This list includes threats and hazards categorized within nine threat groups including:

• Fires;
• Global;
• Health;
• Human Resources;
• Hydrological;
• Technological; and
• Weather.

Within this list, each threat has been assigned a priority level and describes the consequence and likelihood of occurrence and whether or not there is a procedure in place at SaskEnergy to address the issue. The NEB could not confirm the origin of the document because it did not follow the SaskEnergy document control template and was therefore not dated or signed.

Upon review of this All Hazard List, the NEB found that it does not constitute an inventory of identified hazards and potential hazards related to its federally regulated operations. Rather, this document appears to be a tool used in emergency response planning to verify that potential emergency event types that could impact provincial infrastructure have been accounted for, considered and mitigated where required by SaskEnergy.

The NEB determined that the list does not meet the requirements of the OPR s. 6.5 (1)(d) because it does not contain all of the hazards and potential hazards related to federally regulated pipelines nor is it an output of the hazard identification process.

MIPL(C)L also provided the All Hazards Risk Assessment Process. According to the document, its purpose is to describe the process of reviewing the Saskatchewan Risk and Hazard Inventory and define the relevance and impact of the risks and hazards SaskEnergy’s environment. A review of the document indicated that it does not include a methodology to be followed to complete these hazard assessments nor does it link the maintenance of an inventory of identified hazards and potential hazards for its federally regulated pipeline operations.

Although MIPL(C)L provided a list of all-hazards, the Board determined that the list did not constitute an inventory of hazards and potential hazards related to its federally regulated pipeline facilities. In addition, MIPL(C)L did not provide documentation that describes the maintenance of this list or its function within or link to the MIPL(C)L EM Program, therefore it does not meet the requirements of the OPR s. 6.5 (1)(d).

Topic: Management System Sub Element 2.1 Hazards Identification, Risk Assessment and Control

Regulatory Requirement: OPR s. 6.5 (1)(e): establish and implement a process for evaluating and managing the risks associated with the identified hazards, including the risks related to normal and abnormal operating conditions;

The company must have a documented process for evaluating and managing the risks associated with the identified hazards, including the risks related to normal and abnormal operating conditions;

Non-Compliant

MIPL(C)L provided several documents that described the evaluation of risk occurring at the corporate and EM Program level. These documents included:

1. The All Hazards Risk Assessment Process

According to MIPL(C)L, this process is used to review the provincially managed All Hazard List and assess the relevance and impact of the risks and hazards to determine levels of preparedness. However, as noted in AP-08 above, the document does not provide a specific, process describing the methodology to be followed to evaluate and manage the risks. In addition, as this document was released in October 2017, it did not meet the Board’s definition of established because it had not been in place for 90 days at the time of the audit.

2. The UMS Risk Assessment Process and Procedure

This corporate level management system process describes the risk identification and assessment activities within the UMS. The purpose of this process is to help the organization apply a structured and collaborative approach to identify, assess and evaluate risks and determine controls in order to manage the risks appropriately.

The Risk Assessment Process document includes 4 levels of risk. These are listed as:

1. Corporate Level Risk
2. Asset Level Risk
3. Program Level Risk
4. Activity Level Risk

A review of the documentation found that there was a lack of clarity as to what exactly would constitute a risk at each of these levels and how they are linked to one another. Following the review of these documents, the NEB could not determine how the UMS Risk Assessment Process identifies the risks at each of the levels or how it accounts for and integrates any identified hazards at the EM Program Level.

3. The Asset Life Cycle – Risk/Control Register

This document is maintained by the company’s Internal Audit Services group. It identifies 16 high level risks to the company and includes a corresponding list of controls that are available to be applied to manage the risks to a level that is acceptable to the company.

Further review of the document found that “the Inadequate capability to respond to an emergency” was the only risk on the Register directly related to the EM Program. MIPL(C)L did not provide records to demonstrate that this risk from the EM Program was the result of a risk evaluation process. Instead, MIPL(C)L indicated that this risk was added to the Register in 2014 in order to proactively evaluate the controls in place.

Due to the fact that this risk was added to the Register without adhering to a process that includes the evaluation and management of identified hazards and potential hazards, the NEB determined that this document does not meet the requirements of the OPR.

Conclusion

Following the review of each of the documents outlined above, the Board has determined that although some evaluation of risks is occurring related to the EM Program, MIPL(C)L did not demonstrate that it has implemented a documented, systematic process for evaluating and managing the risks associated with identified hazards, including the risks related to normal and abnormal operating conditions.

As a result of the above assessment, the Board has determined that MIPL(C)L is in non-compliance with OPR s. 6.5 (1)(e). The Board requires that a CAPA Plan be developed to address this non-compliance.

Topic: Management System Sub Element 2.1 Hazards Identification, Risk Assessment and Control

Regulatory Requirement: OPR s. 6.5(1)(f): establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards and the risks and for communicating those controls to anyone who is exposed to the risks;

The company must have a documented process for developing and implementing controls to prevent, manage and mitigate the identified hazards and the risks and for communicating those controls to anyone who is exposed to the risks;

Non-compliant

Process for developing and implementing controls

At the corporate level, the UMS Process Safety Management Program document describes threats that relate to natural gas pipeline and distribution systems, and includes a variety of company and industry controls put in place to manage these threats. Risk Controls for Process Safety are owned and managed within the following programs:

• Design and Build (multiple programs);
• Security Management;
• Hazardous Materials;
• Integrity (multiple programs);
• Damage Prevention (pending);
• Corporate Emergency Management;
• Reliability Centred Maintenance (pending);
• Control Room Management; and
• Process Safety.

For Emergency Management, the CEMP was developed to be an overarching coordinated approach between the emergency programs developed at various levels within the Company. The CEMP Manual “incorporates more than fifty control processes that are used to mitigate and respond to threats.” In the document, Appendix I lists fifty control that are used to mitigate and respond to the threats listed in Appendix II that reflect those listed in CSA-Z662-15.

Following a review of the controls listed in Appendix I, the Board found that the list of controls appears to be based on the generally accepted hazards associated with gas facilities including:

• the safety manual;
• valve isolation program;
• First Call;
• Environment audits; and
• NEB Emergency Procedures Resource Manual.

The Board found that while the CEMP document includes a list of various activities, documents and organizations that could contribute to the control of a hazard or threat, the CEMP does not describe the process that was used to develop or maintain this list of controls. Furthermore, the document does not describe how the list of controls has been applied or evaluated to ensure that these controls are adequate for addressing the threats listed by category in Appendix II. Additionally, this list of threats is limited to the threat categories as outlined in CSA Z662-15, which are threats to the integrity of the facilities and would not be considered to be appropriately all inclusive of the hazards and risks that would normally pertain to an EM Program. For example, the list does not address all of the hazards and risks associated with any high consequence areas along the facility rights of way have been included or addressed.

However, MIPL(C)L did not demonstrate that this list is the result of an established and implemented process to be followed for developing and implementing these controls that has been applied within the EM Program.

While the CEMP document includes a list of various activities, documents and organizations that could contribute to the control of a hazard or threat, the CEMP does not describe the process that was used to develop or maintain this list of controls. Furthermore, the document does not describe and no records were provided to show how the list of controls has been applied or evaluated to ensure that these controls are adequate for addressing the threats listed by category in Appendix II.

Communicating Controls

During the audit, MIPL(C)L demonstrated several formal and informal methods to communicate controls related to emergency management to its staff including training, documented procedures, bulletins and information sharing.

MIPL(C)L maintains a documented procedures library known collectively as the Construction, Operation and Maintenance Procedures (COMPs). The documented procedures library is known collectively as the Construction, Operation and Maintenance Procedures (COMPs). The Board noted that this library contains several documented procedures developed to address the hazards associated with incident response.

In addition, MIPL(C)L demonstrated that it communicates hazards by issuing company-wide bulletins and notices when safety issues deemed significant arise. For example, Hazard Highlights are distributed to staff on a regular basis to communicate various hazards and the recommended associated controls. Another example that was provided for review was the Safety Bulletin which was sent to staff to communicate potential hazards related to not taking proper precautions when responding to incidents involving overpressures where controls such as valves may not function as designed.

Staff safety meetings, tailgate meetings, and emergency exercise debriefs, are also forums where MIPL(C)L informs employees of controls that can be used if exposed to identified hazards or risks.

With respect to the communication of hazards and controls to the public, MIPL(C)L provided documentation including records indicating that it did so through its Public Awareness Program. These included publications and brochures such as:

• 2017 MIPL(C)L Neighbour Letter;
• Guide to Landowners; and
• regular face to face meetings with landowners and tenants living on land in proximity to MIPL(C)L facilities.

While MIPL(C)L demonstrated that it is communicating its controls to employees and members of the public who are exposed to the risks, it did not provide a process that ties the development and implementation of controls for the identified hazards and risks with the communication of those controls to anyone who is exposed to the risks.

Conclusion

Based on the assessment, the Board notes that MIPL(C)L has developed a generic list of controls that could be applied to identified threats. The Board also notes that MIPL(C)L demonstrated various means to communicate controls to those persons who may be exposed to these hazards or risks. However, the company did not demonstrate that it has established and implemented a documented, explicit process or processes for the development of appropriate controls based on identified hazards that includes communicating those controls within the EM Program.

As a result of the assessment, the Board has determined that MIPL(C)L is in non-compliance with OPR s. 6.5 (1)(f). The Board requires that a CAPA Plan be developed to address this non-compliance.

Topic: Management System Sub Element 3.2 Operational Control – Upset or Abnormal Conditions

Regulatory Requirement: OPR s. 6.5 (1)(t): establish and implement a process for developing contingency plans for abnormal events that may occur during construction, operation, maintenance, abandonment or emergency situations..

The company must have a documented process to establish and implement a process for developing contingency plans for abnormal events that may occur during construction, operation, maintenance, abandonment or emergency situations.

Non-Compliant

During interviews and through document review, MIPL(C)L indicated that it includes contingency planning within its emergency response activities as part of its execution of the Incident Command System (ICS). In addition, there are references to contingency planning within its emergency response procedures. During emergencies that affect multiple agencies, MIPL(C)L works with the Province of Saskatchewan and participates in the Saskatchewan Emergency Plan. Under this Plan, contingency planning is the responsibility of the Provincial Emergency Management Committee.

Although MIPL(C)L’s documentation mentions the need for contingency planning and notes ICS requirements for contingency plans, the company did not provide a process for the structured development of contingency plans that may become necessary when a successful response is jeopardized by abnormal or unforeseen events or circumstances that may arise during an emergency situation.

As a result of the assessment, the Board has determined that MIPL(C)L is in non-compliance with OPR s. 6.5 (1)(t). The Board requires that a CAPA Plan be developed to address this non-compliance.

Topic: CSA Z662-15 10.5.2 Pipeline Emergencies

Regulatory Requirement: OPR s. 4 (1): When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of

• (b) CSA Z276, if the pipeline transports liquefied natural gas;
• (c) CSA Z341 for underground storage of hydrocarbons;
• (d) CSA Z662-15, if the pipeline transports liquid or gaseous hydrocarbons; and
• (e) CSA Z246.1 for all pipelines.

CSA Z662-15 – clause 10.5.2.1

Operating companies shall establish emergency procedures that include a) procedures for the safe control or shutdown of the pipeline system, or parts thereof, in the event of a pipeline emergency; and

b) Safety procedures for personnel at emergency sites.

Note: Appropriate emergency procedures related to the pipeline, as determined in conjunction with community agencies, should be included.

CSA Z662-15 – clause 10.5.2.2

Operating companies shall regularly consult and inform the public and agencies to be contacted during an emergency (e.g., police and fire departments), as appropriate, about the hazards associated with its pipelines.

Note: If community emergency response plans exist, appropriate methods to consult and inform the public can be determined in conjunction with the community agencies.

CSA Z662-15 – clause 10.5.2.3

Operating companies shall prepare an emergency response plan and make relevant sections or information therein available to local authorities.

Note: CAN/CSA-Z731 should be used as a guide for the preparation of emergency response plans.

CSA Z662-15 – clause 10.5.2.4

Operating companies shall have verifiable capability to respond to an emergency in accordance with their emergency procedures and response plans and shall demonstrate and document the effectiveness of such procedures and plans.

No Non-Compliances Identified.

AP 12-a) Emergency Shutdown Procedures

For the purposes of this audit, the Board verified that MIPL(C)L has emergency procedures that include the safe control or shutdown of the pipeline system, or parts thereof in the event of an emergency. These procedures include safety procedures for personnel located at emergency sites. MIPL(C)L indicated that its staff are trained to respond to emergency events on the provincial gas distribution system as well as the transmission facilities.

Given that the scope of the audit focused on the identification and control of hazards, it should be noted that, the adequacy and effectiveness of these procedures were not included in the review.

L’Office a vérifié par l’examen de la documentation et des entrevues avec des représentants de la société que cette dernière mettait à la disposition des autorités locales les sections ou les renseignements pertinents des manuels d’intervention d’urgence. Les manuels et les renseignements sont fournis par voie électronique ou en format imprimé par l’entremise d’un système contrôlé afin d’assurer que l’information diffusée est à jour.

AP 12-b) Consulting and Informing public agencies / Availability of EM Plans

During the audit, MIPL(C)L stated that, through its affiliation with SaskEnergy/TransGas it regularly consults with and informs the public and agencies to be contacted during an emergency (e.g., police and fire departments) about the hazards associated with its pipelines. It indicated that these activities are primarily managed and implemented as part of the Public Awareness Plan administered by SaskEnergy/TransGas. The plan includes consultation and training with agencies that may be involved during an emergency.

The Board verified through a review of documentation and through interviews with company representatives that the company makes relevant sections of the Emergency Response manuals or information therein available to local authorities. Manuals and information is provided digitally and/or hard copy through a controlled system to ensure current information is provided.

Based on the review conducted and considering the scope of this audit, the Board did not identify any issues of non-compliance in relation to this requirement.

AP 12-c) Emergency Response Exercises

During the interviews, MIPL(C)L stated that the company regularly verifies its ability to respond to an emergency using various types of exercises including table tops and full mock exercises. These exercises are used to assess the ability to respond as well as the suitability of the procedures and response plans. Although the majority of the exercises were conducted on the provincially regulated distribution system, documentation provided during the audit indicated that two of the thirty tabletop exercises and two simulation exercises were completed in 2016/2017 that were specific to the MIPL(C)L assets. It was also noted that a mock exercise is scheduled to be completed for MIPL(C)L in 2018 as well.

Based on the review conducted and considering the scope of this audit, the Board did not identify any issues of non-compliance in relation to this requirement.