ARCHIVED - Emera Brunswick Pipeline Company Ltd. - Audit Report OF-Surv-OpAud-E236 01 - Appendix IV: EBPC Emergency Preparedness and Response Program Audit Evaluation Table

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Appendix IV:
EBPC Emergency Preparedness and Response Program Audit Evaluation Table

1.0 POLICY AND COMMITMENT

1.1 Policy and Commitment Statements

Expectations: The company shall have a policy approved and endorsed by senior management (the Policy). It should include goals and objectives and commit to improving the performance of the company.

References:[1]
OPR-99 sections 4, 47 and 48
CSA Z662-07 Clause 10.2.2

Assessment:
EBPC demonstrated that it has an emergency management (EM) policy in place that is endorsed by Management and communicated throughout the company. The EM policy is contained within a document titled: Brunswick Pipeline, An Emera Company, Emergency Preparedness and Response (EPR) Program updated May 2010.

Interviews conducted with field technicians, District Manager and Lands and Public Awareness Coordinators (Coordinators) verified that staff are aware of the EM policy. They noted that the policy is reinforced in the procedures.

Interviews with the Operator’s Area Manager and Coordinators verified that EBPC management supports the EPR Program. Monthly safety meetings allow all staff to raise issues and provide management with feedback. Feedback and action items are recorded at every meeting to ensure they are addressed and tracked. EBPC has provided the resources to support the EPR Program including the cost of conducting exercises and new equipment as required.

Based on interviews and documents reviewed, the Board verified that EBPC has formally endorsed its EPR policy and communicated the policy at all levels of the organization.

Compliance Status: Compliant

[1] Each “Reference” in this table contains specific examples of the “legal requirements” applicable to each element but are not necessarily a complete list of all applicable legal requirements.

2.0 PLANNING

2.1 Hazards Identification, Risk Assessment and Control[2]

Expectations: The company shall be able to demonstrate a procedure to identify all possible hazards. The company should assess the degree of risk associated with these hazards. The company should be able to support the rationale for including or excluding possible risks in regard to its environment, safety, integrity, crossings and awareness and emergency management and protection programs (management and protection programs). The company should be able to implement control measures to minimize or eliminate the risk.

References:
OPR-99 sections 4(2), 37, 39, 40, 47, 48
CSA Z662-07 Clauses 10.2, 10.3.2

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program for the Brunswick Pipeline and associated facilities. On an annual basis, the Operator holds a meeting of the Area Manager, District Managers and Coordinators to discuss the Emergency Preparedness and Response Program with several standing agenda items including:

  • the review of EPR risks
  • review of the existing hazards including probability studies to determine the emergency planning zones for the pipeline
  • planning EPR activities such as exercises
  • a discussion of the appropriateness of the emergency planning zone (EPZ) calculations

The Board also reviewed the EPR related procedures and processes. The Operator’s EHS MS Performance Standard 2.0 EHS Risk Management (Performance Standard) sets out the procedure for identifying hazards, assessing those hazards, determining levels of risk posed by the hazards and the controls needed to mitigate the risks. The current Performance Standard identifies a range of environment, health and safety hazards that could pose risks to people and environmental end points. The Performance Standard also includes the requirements for assessing the primary hazards posed by the Brunswick Pipeline system. An Operational Controls Table is used to maintain an inventory of the identified hazards, risk assessments, reference to legal requirements and established controls according to activity. For example, thermal radiation was identified as a hazard. In the design phase of the Brunswick Pipeline the company conducted probability studies based on risk of fatality and where those studies resulted in an emergency planning zone smaller than that used by Maritimes & Northeast Pipeline (M&NP) (which was based on thermal radiation studies), Brunswick Pipeline elected to adopt an emergency planning zone consistent with the M&NP similarly designed pipeline of same diameter and operating pressure. This EPZ formed the basis for design of the ERP to establish response procedures.

The Performance Standard should include all possible hazards to the public, responders, property and the environment. It should also include the level of risk posed by each hazard as well as the risk ranking and appropriate control measures for the purpose of emergency response planning. However, the Board could not verify that these procedures as implemented met the full intent of the Performance Standard or that the list of hazards was exhaustive for the Brunswick Pipeline facilities.

The Operator did not demonstrate that it has ensured the full implementation of its process for identifying all of the hazards and determining appropriate control measures for emergency response planning.

Compliance Status: Non-compliant

[2] Hazard: Source or situation with a potential for harm in terms of injury of ill health, damage to property, damage to workplace environment, or a combination of these. Risk: Combination of the likelihood and consequence(s) of a specified hazardous event occurring

2.2 Legal Requirements

Expectations: The company shall have a verifiable process for the identification and integration of legal requirements into its management and protection programs. The company should have a documented procedure to identify and resolve non-compliances as they relate to legal requirements which includes updating the management and protection programs as required.

References:
OPR-99 sections 4, 6, 32, 40, 47 and 48
CSA Z662-07 Clause 10.2.2(g)

Assessment:
The EBPC Manager of Regulatory Affairs described the process that is in place to monitor regulatory changes related to the ERP for the Brunswick Pipeline. The requirements included in legislation, regulations, standards, advisories and other applicable regulatory information are tracked. Any changes or updates undergo strategic analysis to identify business impacts and required operational changes. Then, action plans are developed and implemented. All regulatory changes are captured and an annual summary of regulatory changes is broadly distributed throughout the Operator’s organization. The EBPC Manager of Regulatory Affairs also tracks the conditions of certificate GC-110 and all commitments made by EBPC in the GH-1-2006 proceeding on an Excel spreadsheet.

The EPR Program includes a process to identify and integrate legal requirements from regulations and conditions of the certificate GC-110 into the program. The applicable sections of the OPR-99 related to EM are integrated into the EPR Program and the ERP. EBPC updates the ERP on an annual basis and files copies of the updates with the NEB in accordance with its document control procedures. The Board also confirmed that EBPC is in compliance with the conditions of certificate GC-110 that relate to EPR.

EBPC was able to demonstrate through interviews and documents reviewed that it has a process to identify and integrate legal requirements into its EPR Program.

Compliance Status: Compliant

2.3 Goals, Objectives and Targets

Expectations: The company should have goals, objectives and quantifiable targets relevant to the risks and hazards associated with the company’s facilities and activities (i.e. construction, operations and maintenance). The objectives and targets should be measurable and consistent with the Policy and legal requirements and ideally include continual improvement and prevention initiatives, where appropriate.

References:
OPR-99 sections 40, 47 and 48
CSA-Z662-07 Clause 10.2.2(h)(ii)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program. The Operator’s EHS MS Performance Standard EHS Objectives Targets and Strategies 7.1 sets out the goals, objectives and targets relevant to the risks and hazards associated with the EBPC facilities and activities. It was verified through the Environment and Safety Program assessments that the Operator was in compliance with this element as it relates to the ERP. Full descriptions of the related Safety and Environments programs are provided in Appendix II: EBPC Safety Program Audit Evaluation Table and Appendix III: EBPC Environmental Protection Program Audit Evaluation Table.

Compliance Status: Compliant

3.0 IMPLEMENTATION

3.1 Organizational Structure, Roles and Responsibilities

Expectations: The company shall have an organizational structure that allows its management and protection programs to effectively function. The company should have clear roles and responsibilities, which may include responsibilities for the development, implementation and management of the management and protection programs.

References:
OPR-99 sections 40, 47 and 48
CSA-Z662-07 Clauses 10.2.2(b), 10.3.2.4

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

Various members of the Operator’s operational personnel are assigned roles and responsibilities under the EPR Program. EPR roles are assigned to appropriate personnel and tested on an annual basis through full scale mock exercises as well as table top exercises. Interviews with the several technical staff verified that they understand their roles and responsibilities. Interviews and documentation reviewed determined that the Operator has established a suitable organizational structure for the purposes of, implementing and maintaining the EPR Program for the Brunswick Pipeline. The Operator demonstrated that it has the capacity to respond to an emergency based on the training received by personnel, the exercises conducted and the training of mutual aid partners.

The Operator was able to demonstrate that it has developed roles and responsibilities to ensure the effective implementation of its EPR Program.

Compliance Status: Compliant

3.2 Management of Change

Expectations: The company shall have a management of change program. The program should include:

  • identification of changes that could affect the management and protection programs;
  • documentation of the changes; and
  • analysis of implications and effects of the changes, including introduction of new risks or hazards or legal requirements.

References:
OPR-99 section 6
CSA-Z662-07 Clause 10.2.2 (g)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

The Operator’s EHS MS Management of Change Performance Standard 2.7 sets out the expectations for the management of change (MOC) and how those changes will be incorporated into the necessary operational policies and standards. On an annual basis, EBPC and the Operator review and update the EPR Program to identify and assess any changes that may affect the EPR program. The analysis includes the results of emergency response exercises, continuing education and liaison programs, and changes to operating conditions of the pipelines.

At the time of the audit the Operator did not have a fully implemented MOC program to identify changes that could affect the EPR Program, including introduction of new risks, hazards or legal requirements and documenting these changes. The Board determined that the MOC process is only partially implemented as described in the standard by various technical areas including emergency management. For example, the Board could not verify that the annual review of the list of hazards was exhaustive for the Brunswick Pipeline facilities or that results of exercises were incorporated into the emergency management program, and therefore the identification of changes that could affect protection programs may not be complete. As such, the Board could not confirm the effectiveness of the MOC program. The Board noted that the Operator had identified this issue as part of its 2008 internal audit and has committed to corrective action.

Compliance Status: Non-compliant

3.3 Training, Competence and Evaluation

Expectations: The company shall have a documented training program for employees and contractors related to the company’s management and protection programs. The company shall inform visitors to company maintenance sites of the practices and procedures to be followed. Training requirements should include information about program-specific policies. Training should include emergency preparedness and environmental response requirements as well as the potential consequences of not following the requirements. The company should determine the required levels of competency for employees and contractors. Training shall evaluate competency to ensure desired knowledge requirements have been met. Training programs should include record management procedures. The training program should include methods to ensure staff remains current in their required training. The program should include requirements and standards for addressing any identified non-compliances to the training requirement.

References:
OPR-99 sections 28, 34, 35, 46 and 56
CSA Z662-07 Clauses 10.2.2(c), 10.3.2.4

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program including employee training. There are several elements of the employee training program. The Operator’s EHS Management System Performance Standard 1.4 EHS Training outlines minimum training expectations and requirements for all operational employees as well as the frequency that the training is required to be considered current. In addition to EHS training requirements, the EPR Program for the Brunswick Pipeline includes additional training requirements for operations staff. The EPR training program includes at a minimum:

  • attendance at related conferences and workshops,
  • training in the Incident Command model for managing emergencies
  • media relations, and
  • crisis communication training

The training is complemented by:

  • formal group and individual review of the emergency response plan and sign-off by the employee completing the review,
  • tabletop or communications exercises,
  • critique of the emergency response plans, and
  • completion of any identified deficient training related to the use of response equipment.

Interviews verified that all personnel that have an emergency response role receive appropriate levels of training for the respective roles in accordance with the EHS Management System Performance Standard 1.4 EHS Training and the EPR Program. In addition, all field technicians and other personnel receive core safety training. While the field technicians are not provided specific emergency management training, they receive training in company emergency response procedures through participation in several emergency response exercises per year, including at least six table top exercises and one full scale mock emergency exercise. For cross-training purposes, personnel rotate through Incident Command roles such as incident commander, on-site supervisor, safety officer and liaison officer. In addition to participating in exercises, the Coordinators and District and Area Managers receive additional training in incident command and emergency operations centre management from the provincial Emergency Measures Organization (EMO). The competency of the responders is verified by written examination that is completed after training is received from the provincial EMO. Examination of training records for field technicians verified participation in emergency response exercises. The hard copy training records of all employees are filed and tracked by administrative staff and training requirements are managed by the Learning Management System (LMS) that tracks training completion and generates an e-mail to the employee and his or her manager when training is due. Field technicians noted that although there is not a field operator qualification procedure in place for Brunswick Pipeline, it will soon adopt the Field Operator Qualification Procedure that is under development by the Operator.

At each office or field location visited, the auditors were signed-in to the site, given a site orientation, and informed of the safety and emergency procedures to be followed in the event of an emergency.

Through the Operator’s continuing education and liaison program, first responders such as fire departments, police and emergency health services, the New Brunswick and Nova Scotia EMOs, the public, pre-qualified contractors and other persons who may be involved in an emergency on the EBPC system are educated and receive training as required for their respective roles. Documents reviewed verified that the continuing education forums and emergency response exercises are very well attended by company personnel, first responders and others who may have a role, and that the forums and exercises are conducted several times per year according to a well planned and managed schedule. Due to the unique setting of the EBPC pipeline through the City of Saint John, the Operator has conducted extensive meetings and education programs with the City of Saint John fire department, police and Saint John EMO, which included conducting a full scale emergency exercise within the City of Saint John in 2009 with all response agencies involved.

The Operator was able to demonstrate that it provides and manages adequate emergency response training for employees.

Compliance Status: Compliant

3.4 Communication

Expectations: The company should have an adequate, effective and documented communication process(s):

  • to inform all persons associated with the company’s facilities and activities (interested persons) of its management and protection programs policies, goals, objectives and commitments;
  • to inform and consult with interested persons about issues associated with its operations;
  • to address communication from external stakeholders;
  • for communicating the legal and other related requirements pertaining to the management and protection programs to interested persons;
  • to communicate the program’s roles and responsibilities to interested persons.

References:
OPR-99 sections 28, 29,33, 34, 35
CSA Z662-07 Clauses 10.2.2(d), 10.3.2.2, 10.3.2.3

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program. The Operator has a documented Continuing Education and Liaison Program in place to educate the public, first responders and contractors that may have a role in response to an emergency on the Brunswick Pipeline. Document review verified the content of information package that is provided to stakeholders, including information on pipeline safety, emergency preparedness, what to do if there is a suspected pipeline emergency and company contact information. Communication tools include hand delivery of information brochures to residents within the EPZs, annual information letters to all residents within the EPZs, first responder booklets, presentations to first responders, forestry operators, landowners and municipalities, video presentations, meetings, personal visits to landowners, and public awareness presentations. The Coordinator tracks the activities and schedules of events in binders.

Communications under the EBPC Public Relations and the Operator’s awareness program address:

  • EPZ residents
  • Schools - including a natural gas education program
  • Fire departments, police, EMOs and Emergency medical services
  • Communities and interest groups
  • Forestry operators
  • Municipal, provincial and federal government
  • Contractors

The Public Awareness Plan serves as a formal communication guide and to educate the public and others of the responsibilities of working safely near the pipeline. The target audiences include landowners, excavation contractors, forestry contractors and other identified parties who may live and work around the pipeline.

Accu-link call system is a 24-hour call system reached through the EBPC 1-800 number. The Accu-link centre will manage all calls received by EBPC for any reason. In the event of a phone call to report a potential pipeline emergency, the Accu-link centre records essential information on the nature of the emergency, caller contact information, location of the caller and location of the potential emergency. The call is immediately referred to the on-call duty officer and an electronic ticket is generated. The Accu-link system also receives calls related to line locate requests and work proposed on the EBPC right-of-way (RoW). For any work proposed within 500 metres of the EBPC RoW, the caller is referred to the Operator for review and approval of the work. The call system was tested as part of the audit during non-business hours which confirmed the system functions as described.

The Operator was able to demonstrate that it has communication processes to inform all persons associated with its facilities and activities of its EPR Program.

Compliance Status: Compliant

3.5 Documentation and Document Control

Expectations: The company should have documentation to describe the elements of its management and protection programs- where warranted. The documentation should be reviewed and revised at regular and planned intervals. Documents should be revised immediately where changes are required as a result of legal requirements or where failure to make immediate changes may result in negative consequences. The company should have procedures within its management and protection programs to control documentation and data as it relates to the risks identified in element 2.0.

References:
OPR-99 sections 27 and 32
CSA-Z662 Clause 10.2.2(e), (f), 10.3.1.1(d)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

The Operator has developed a documented EPR Program that describes the elements of its EM Program. The EPR Program includes elements such as: risk assessment, liaison program, continuing education program, emergency preparedness manuals, training, validation, document control, policy, goals and program review. The EPR Program is reviewed and revised as necessary during the annual management review process with EBPC Management.

The Brunswick Pipeline Field ERP sets out the company response procedures in the event of a pipeline emergency on the Brunswick Pipeline in New Brunswick. The document is current to January 2010 and, in accordance with the EPR Program, it undergoes management review on an annual basis. Review of the minutes of the annual meeting demonstrates that the ERP is a standing agenda item for the annual review and has undergone minor revisions in the most recent review. The ERP contains the appropriate sections and content to enable the Operator to deal with an emergency, including but not limited to: levels of alert, response team structure, mutual aid, command posts, initial action and notification, flowcharts, role descriptions, responder safety, EPZ isolation, public safety, ignition guidelines, government roles, post incident procedures, maps, forms, training and exercises, etc. Interviews and site visits confirmed that the ERP is contained in all field vehicles and offices and is tested through the training program and exercise program. It is a living document that is controlled and used regularly for exercises and training.

The Operator has implemented a document control procedures that includes the ERP and emergency response mapping are also controlled and distributed to appropriate agencies and First Responders that may have a role in an emergency. Urban and rural fire departments have copies of the emergency response mapping for their respective regions and receive updates as required through the document control process. The provincial fire marshals and the Saint John Fire Department hold controlled copies of the Emera emergency procedures manual.

Under certificate GC-110 conditions 18 and 19, EBPC is required to file the ERP with the Board at least 60 days prior to operation of the pipeline and to consult with stakeholders in the development of the ERP. The ERP and evidence of consultation was filed with the Board within the required time frames. EBPC and the Operator conducted considerable consultation with the communities, the City of Saint John, the Fire Department, Police, EHS and City of Saint John EMO in order to develop the best possible emergency response plan that meets the needs of the stakeholders and addresses public safety, responder safety and protection of property and the environment.

Compliance Status: Compliant

3.6 Operational Control - Normal Operations

Expectations: The company should establish and maintain a process to develop, implement and communicate mitigative, preventive and protective measures to address the risks and hazards identified in elements 2.0 and 3.0. The process should include measures to reduce or eliminate risks and hazards at their source, where appropriate.

References:
OPR-99 sections 27-49
CSA Z662-07 Clauses 10.2.2(f), 10.3.1

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

The Operator’s EPR Program establishes and maintains the processes to develop, implement and communicate mitigative, preventive and protective measures to address the risks and hazards posed by the Brunswick Pipeline. Through its continuing education, liaison and public awareness programs EBPC has established processes to communicate the mitigative, preventive and protective measures.

Compliance Status: Compliant

3.7 Operational Control - Upset or Abnormal Operating Conditions

Expectations: The company shall establish and maintain plans and procedures to identify the potential for upset or abnormal operating conditions, accidental releases, incidents and emergency situations. The company shall also define proposed responses to these events and prevent and mitigate the likely consequence and/or impacts of these events. The procedures must be periodically tested and reviewed and revised where appropriate (for example, after emergency events).

References:
OPR-99 sections 32, 35 and 52
CSA-Z662-07 Clause 10.3.2

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

The Operator has an ERP in place for the operation of the Brunswick Pipeline. The ERP is updated annually, and is a controlled document. The ERP and any updates are filed with NEB as required. Based on the hazards identified, the ERP includes appropriate roles, equipment, procedures, etc. The ERP also contains a description for the training of company personnel, first responders and contractors are tested on a scheduled basis through full scale mock and table top exercises. EBPC along with the Operator regularly consults and informs the public, agencies and first responders (fire departments, police and EHS) about the locations of its pipelines and facilities, the hazards associated with its pipeline system, the procedures to follow in the event of an emergency, and the names and contact numbers of the company in order to report any suspected or actual pipeline emergency.

The Operator has a documented incident reporting procedure and conducts debrief sessions upon completion of exercises in order to review and learn, and revise the EPR Program as required.

Compliance Status: Compliant

4.0 CHECKING AND CORRECTIVE ACTION

4.1 Inspection, Measurement and Monitoring

Expectations: The company shall develop and implement surveillance and monitoring programs. These programs should address contract work being performed on behalf of the company. These programs should include qualitative and quantitative measures for evaluating the management and protection programs and should, at a minimum, address legal requirements as well as the risks identified as significant in elements 2.0 and 3.0. The company should integrate the surveillance and monitoring results with other data in risk assessments and performance measures, including proactive trend analyses. The company shall have documentation and records of its surveillance and monitoring programs.

References:
OPR-99 sections 36, 39, 47, 48, and 53(1)
CSA Z662-07 Clauses 10.2.2, 10.3.2.4, 10.14.1

Assessment:
Surveillance and monitoring processes and procedures are documented under the Public Awareness and Crossings Programs. Please refer to Appendix V: EBPC Crossings Program Audit Evaluation Table and Appendix VI: EBPC Public Awareness Program Audit Evaluation Table for details on EBPC’s inspection, measurement and monitoring programs as it relates to EPR.

Compliance Status: N/A

4.2 Corrective and Preventive Actions

Expectations: The company shall have a process to investigate incidents or any non-compliance that may occur. The company shall have a process to mitigate any potential or actual issues arising from such incidents or non-compliances. Such mitigation may include appropriate timing and actions for addressing the issues that arise. The company shall demonstrate that it has established a documented procedure to:

  • set criteria for non-compliance;
  • identify the occurrence of any non-compliances;
  • investigate the cause(s) of any non-compliances;
  • develop corrective and/or preventative actions; and
  • effectively implement the required corrective and/or preventative actions.

The company should develop procedures to analyze incident data in order to identify deficiencies and opportunities for improvement in its management and protection programs and procedures.

References:
OPR-99 sections 6 and 52
CSA-Z662 Clauses 10.2.2(g) and (h)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

The Operator has documented standard guidelines for incident reporting as required by OPR-99 section 52 and for incident investigation. The incident reporting process is set out in the Brunswick Pipeline ERP and addresses the requirements of OPR-99 section 52. The ERP also includes a post incident evaluation and overview of the post incident report. The Operator’s EHS MS Incident Learning and Prevention Performance Standard 8.1 sets out the incident investigation procedures.

Within its first year of operation, the Operator conducted a full scale mock exercise to test several elements of the Brunswick Pipeline EPR Program. The exercise was planned and conducted to meet the requirements of the GH-1-2006 certificate condition 21. The exercise met the requirements of condition 21 and there is documentation that supports the planning and implementation phases of the exercise, the feedback received from participants and the actions put in place in response to participant feedback.

In meeting condition 21, EBPC filed its summary with the Board that included a description of how it responded to the feedback from participants. However, the Board could not confirm that the process for incorporating lessons learned into the ERP had been implemented. There was no documentation showing that the feedback received from participants, the lessons learned from the exercise and the actions put in place to address suggested improvements were integrated into the EPR Program. There is no documentation demonstrating that completion of the actions is tracked and verified.

The Operator did not demonstrate the implementation of a process for tracking, assigning actions and verifying completion of actions from the lessons learned in its table top and full scale emergency response exercises.

Compliance Status: Non-compliant

4.3 Records Management

Expectations: The company shall establish and implement procedures to ensure that the records supporting the management and protection programs are retained, accessible and maintained. The company shall, as a minimum, retain all records for the minimum lengths of time as required by the applicable legislation, regulation and standards incorporated by reference into the regulation.

References:
OPR-99 sections 32, 47, 48, 52, and 56
CSA-Z662-07 Clause 10.2.2(e)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

It was verified that training records, monthly inspection reports, budgets, compliance reports, manuals and other documents are managed and tracked through programs such as System and Integrity Logging, the LMS and the Operator’s web portal.

Records of landowner contact information are part of the EPR program. The Operator maintains landowner contact information in a database. Inputs to the landowner database include information received in response to the annual letter to all landowners along the Brunswick Pipeline, GIS data, provincial EMO data, City of Saint John data and title searches as required. As the landowner database is incorporated into the Brunswick Pipeline Emergency Response Mapping, there is potential for changes in land use and ownership to affect the ERP. For that reason, the landowner database is reviewed annually.

The Operator was able to demonstrate that it manages and maintains operational records related to the EPR.

Compliance Status: Compliant

4.4 Internal Audit

Expectations: The company shall develop and implement a documented process to undertake audits of its management and protection programs and procedures. The audit process should identify and manage the training and competency requirements for staff carrying out the audits. These audits shall be conducted on a regular basis.

References:
OPR-99 sections 53 and 55
CSA Z662-07 Clause 10.2.2(c) and (h)(iii)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPR Program.

The Operator’s EHS Management System Performance Standard 9.1 EHS Audits documents the internal audit program. The performance standard sets out a 3 year cycle for all operational internal audits. The EBPC Manager of Regulatory Affairs indicated that due to the short time frame that the Brunswick Pipeline has been in operation (less than one year prior to the NEB audit); it had not yet conducted an internal audit of its programs.

The Board recommends that the Operator amend its internal audit program to ensure requirements identified in OPR-99 and other referenced and regulatory documents are appropriately defined (see also Element 2.2 Legal Requirements) and that internal audits incorporate all regulatory requirements that apply to the Brunswick Pipeline and facilities. Further, during the audit, EBPC staff provided documentation of its parent company’s internal environmental management system which includes internal audit requirements. EBPC staff indicated that it was EBPC’s intention to ensure that practices implemented reflect the Emera Inc. environmental management system requirements. If the audit process is implemented as proposed, it could result in an effective and fully compliant process.

Compliance Status: Compliant with recommendation

5.0 MANAGEMENT REVIEW

Expectations: Senior management should formally review the management and protection programs for continuing suitability, adequacy and effectiveness. The review should be based on appropriate documentation and records including the results of the surveillance, monitoring and audit programs. This review should be formal and documented and should occur on a regular basis. The management review should include a review of any decisions, actions and commitments which relate to the improvement of the programs and the company’s overall performance.

References:
OPR-99 section 55
CSA Z662-07 Clause 10.2.2(h)(iii)

Assessment:
See Appendix VII for the assessment of this element.

Compliance Status: See Appendix VII for the assessment of this element.

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