Emergency Response Exercise The Straits of MackinacFunctional ExerciseConducted: September 24, 2015 —After Action Report/ Improvement Plan

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Table of Contents

01 Executive Summary

02 Exercise Design

7 Learnings

10 Conclusion

11 Appendix A: Participants

“ The scope and number of participants involved in the exercise was impressive—it certainly made it clear that emergency management is taken seriously.” —National Energy Board (NEB)

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An Enbridge Enterprise Emergency Response Team (E3RT) emergency response exercise, held in Michigan’s Straits of Mackinac in September 2015, involved more than 700 individuals representing federal, state, local community and response agencies.

Executive Summary

Enbridge led the exercise with the support of a multi-jurisdictional planning team, and mobilized numerous pieces of response and recovery equipment that were deployed both on land and on water. and in the air (Enbridge and USCG helicopters).

This E3RT exercise was conducted as part of the multi-pronged safety approach that Enbridge uses to keep its pipeline network safe. Safety is at the very foundation of Enbridge’s business, and this exercise—like others the company has held in the region—was one of numerous precautions Enbridge takes, on an ongoing basis, to promote the continued safe, reliable operation of its Line 5 pipeline.

Lessons previously learned from Enbridge’s full-scale emergency response exercise,carried out in September 2014 in Indian River, Mich., were implemented and helped lead to the overall success of this E3RT exercise. These included: early and continued involvement of local agencies in exercise design and planning; engaging with local tribal representatives; and the execution of an Incident Command System (ICS)

201 development workshop. This ICS 201 workshop was an industry first, and drew high praise from the regulators and exercise participants, ensuring alignment and context prior to the exercise.

Notable comments from regulators, partner agencies and participants included:

• “The exercise was impressive”;

• “The exercise felt realistic”;

• “The exercise was well planned”;

• “Great participation”; and

• Integration of local resources into the response went well.”

During the exercise, the Incident Management Team, operating under a Unified Command, implemented the strategies and tactics identified in Enbridge’s Integrated Contingency Plan, the Straits of Mackinac Tactical Response Plan, and the local Area Contingency Plan. All exercise objectives and regulatory requirements were met by participants during this E3RT exercise. This was documented through the completion of exercise injects managed by a truth/control cell and an evaluation team with representation from peer companies,

regulatory agencies and subject

matter experts.

Numerous types of response,

recovery and containment equipment

were deployed in the Straits of

Mackinac—including six U.S. Coast

Guard vessels, 19 skimmers, 33 small

boats and more than 5,000 feet of

sorbent boom—to support tactical

operations identified during the

exercise planning process, with no

gaps identified during deployment.

As with all exercises, areas for

improvement were identified

during the exercise hot wash and

post-exercise After Action Meeting,

and are noted within this document.

An improvement plan has been

developed; any corrective actions

will be implemented during future

exercises, shared with all Enbridge

business units and, as appropriate,

also shared with industry peers.

Some high-level learnings have also

been shared with area residents to

help demonstrate our commitment

to protecting the Straits of Mackinac

and our ability to respond effectively

and appropriately in the unlikely event

an incident should occur.

2Exercise Design

Background

This exercise was focused on a one-day, proactive-phase, command post event, simulating a response in the Straits of Mackinac. The exercise focused on the proactive phase response capabilities of the Incident Management Team, specifically regarding communication processes, operational response management, public affairs and command and control of the incident. The incident was managed by an Incident Command System Unified Command, consisting of Federal, State and local agency On-Scene Coordinators (OSC) and a fully integrated Incident Management Team with personnel from Enbridge, federal, state and local agencies and response contractors.

The E3RT exercise began on the morning of September 24, 2015 with an ICS 201 Incident Brief and an operational safety brief. Participants then began the development of a Period 2 Incident Action Plan (IAP).

Enbridge holds exercises, drills and equipment deployment events throughout the year to prepare and train its teams on Emergency Response Plans, which assist in identifying areas for continual improvement. The execution of these exercises requires months of preparation and planning.

Operational Period

Rea

ctiv

e P

hase

Pro

activ

e P

hase

Tactics Meeting

Preparing for the Tactics

Meeting

Preparing for the Planning

Meeting

Planning Meeting

IAP Prep & Approval

Operatings Briefing

New Ops Period Begins

Execute Plan & Assess Programs

Command & General Sta�

Meeting

IC/UC Develop/Update

Objectives Meeting

Prep for UC Objectives Meeting

Situation Status Update

Initial UC Meeting

Incident Brief ICS Form 201

Initial Response& Assessment

Notifications

Incident/Event

The Planning Cycle

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“A very productive trip that has helped us to

better understand the scope of a response

on the Straits.” —National Regulator

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Planning

The exercise design team consisted of Enbridge employees; federal, state and local agencies; law enforcement; area tribes; and Enbridge’s key response contractors. The Concept and Objectives meeting was January 20, 2015 in St. Ignace. Planning officially started on February 18, 2015, and, over several months, led to development of the exercise purpose, scope, objectives, scenario details, exercise logistics, organization and resource requirements. Exercise planning focused on command, control and coordination of a simulated event, and meeting the National Preparedness for Response Exercise Program (NPREP) guidelines exercise components.

Included in the planning timeline were:

• An information sharing workshop for local participating agencies;

• A Master Scenario Event List (MSEL) conference calls for participating agencies to provide input into the inject list for the exercise; and

• A consultation/information briefing for tribal communities.

Planning Timeline

January 20, 2015 Concept and Objectives Meeting

February 18, 2015 Initial Planning Meeting

March 18, 2015 Planning Conference Call

April 16, 2015 Planning Conference Call

May 13, 2015 Mid Planning Meeting

May 14, 2015 Information Sharing Workshop

June 17, 2015 MSEL Planning Conference Call

July 20, 2015 Information Briefing to Tribes

July 30, 2015 Planning Conference Call

August 7, 2015 Planning Conference Call

September 17, 2015 Final MSEL Conference

September 22, 2015 Role Specific Training

September 23, 2015 Role Specific Training and 201 Workshop

September 24, 2015 Exercise

September 25, 2015 After Action Meeting with Design Team, Evaluator Team and Participating Agencies

Exercise Design (continued)

U.S. Coast Guards review measurements of water temperature, depth and light penetration—key water quality parameters that affect many aspects of aquatic life.

5Exercise Design (continued)

Scenario

At 5:30 a.m. on September 23, 2015, Enbridge’s Control Center in Edmonton, Canada recognized a pressure drop in the company’s pipeline network and initiated an emergency shutdown. The system was completely shut down and isolation of the line achieved within 10 minutes.

• The Control Center also called the Superior Region on-call manager and informed them of the situation. It was later estimated that approximately 4500 barrels of light crude were released.

• Superior Region takes action. The on-call manager called an Enbridge staff member working

out of Mackinaw City and asked him to immediately go to the site and confirm evidence of a release.

• Immediately afterwards, the on-call manager called the Superior Regional Director to advise him of a release. The region called the U.S. Coast Guard’s National Response Center to inform them of the release (exercise participants listened to this notification call).

• Due to location and the sensitivity of the area, the Regional Director activated Superior’s Field Response Teams, the regional Incident Management Team (IMT) and Incident Command Post in accordance with the Superior

Region Integrated Contingency Plan (ICP) and Straits of Mackinac Tactical Response Plan.

• Passersby called 911 as a hydrocarbon odor was detected in the general area of the bridge. The Enbridge staff member, while conducting a reconnaissance with members of the St. Ignace Fire Department, saw an oily sheen on the surface of the water from the bridge.

• Police called the Control Center to report the odor, and were advised that an Enbridge responder (Mackinaw City staff member) had been dispatched was on location. Police were also told that Enbridge activated its FRT and IMT.

Enbridge Field Response Team deploys boom at one of the exercise Control Points.

6Exercise Design (continued)

Exercise Objectives

All exercise objectives established by the design team were met by the participants. These objectives included:

• Testing specific tactical components of the Straits of Mackinac Tactical Response Plan.

• Working toward the development of a Period 2 Incident Action Plan under Unified Command.

• Practicing containment and recovery for open water by Oil Spill Response Contractor (OSRO) and In-Shore Field Response teams.

• Establishing a Joint Information Center (JIC), and producing unified and consistent messaging with internal and external organizations.

• Practicing Liaison function and information sharing/passage to participating agencies, with a view to achieving a Common Operating Picture (COP).

• Testing Command Post layout and functionality.

Additionally, Enbridge participates in the National Preparedness for Response Exercise Program (PREP). This exercise was designed to meet PREP requirements, which satisfies the exercise requirements of the U.S. Coast Guard (USCG), the U.S. Environmental Protection Agency (EPA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA). This exercise fulfilled the following PREP components that were identified by the exercise design team:

• Notifications

• Staff Mobilization

• Operate w/in response system in response plan

• Discharge Control

• Assessment of Discharge

• Containment of Discharge

• Recovery of Spill Material

• Protection of Sensitive Material

• Disposal of recovered material and debris

• Communications

• Transportation

• Personnel Support

• Equipment Maintenance and Support

• Procurement

• Documentation

Assumptions, Artificialities and Out of Play

• Incident investigation was not exercised.

• There was no operations control over deployed resources.

• There were no “hidden agendas” or trick questions.

• All players received information at the same time.

• No multiple Incident Command Posts.

• No search and rescue element.

• No salvage operations.

• No terrorism element.

Exercise Control

Because the duration and the scope of this exercise were limited, certain details were simulated via a well-staffed Truth Cell made up of simulators and controllers. The physical description of what would fully occur at the incident sites and surrounding areas was relayed to players by the simulators or controllers. Exercise simulators and controllers acted as media, private citizens, land owners, vendors, government officials, and other stakeholders to seek answers, register concerns or prompt action during the simulated spill in the form of injects. These injects facilitated exercise play and recorded the completion of exercise objectives.

Participants

More than 700 individuals either participated in or observed the exercise, representing more than 40 agencies and community organizations. A full list of participating agencies and observing organizations is found in Appendix A.

The Response Group (TRG) reviewing the ‘Planning P’ to generate an Incident Action Plan.

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exercise participants, through facilitated discussions, to develop the initial exercise framework and response actions. The workshop also removed the initial confusion found at exercises that typically start off with a verbal briefing of the initial actions; participants were well aware of the initial actions taken, which allowed them to quickly jump into their assigned roles and responsibilities. The workshop was highly praised by all participants, and deemed an industry-leading initiative.

Learnings

This exercise was developed to support familiarity with response plans and processes, and fulfill regulatory requirements.

All lessons learned will be implemented across Enbridge’s business units to strengthen the company’s Emergency Response (ER) program, and will also be with industry partners and will also be “shared” with industry and other stakeholders.

Previous Learnings (Indian River Full-Scale Exercise, 2014)

The 2014 Indian River exercise resulted in learnings that were targeted by the exercise design team as actions for this Straits of Mackinac exercise—specifically, the ICS 201

workshop, information exchange workshop, and involvement with local agencies and tribal representatives.

2015 E3RT Exercise Successes

• Engaged local agencies early during exercise design and planning, and facilitated their involvement and participation in planning and executing the exercise.

• Engaged in early and continuing dialogue with area tribal representatives.

• Developed and implemented an ICS 201 workshop, which allowed

Shoreline Cleanup Assessment Techniques (SCAT) team surveys the area on the north shore of the Straits.

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• In the weeks leading up to and during the week of September 24, Enbridge successfully planned and managed three major events—this exercise in the Straits of Mackinac; planned hydrotests of Line 2B in Minnesota and of Line 9 in Ontario. This is a testament to the bandwidth and capabilities of the organization, since the company’s Enbridge Enterprise Emergency Response Team (E3RT) includes staff from across its North American enterprise.

• In-house improvements to tactical equipment proved beneficial.

2015 E3RT Exercise Lessons Learned

• Continue to deliver ICS role-specific training, and encourage involvement of non-operations functions in exercises outside the E3RT.

• Expand E3RT staffing to include administrative support for each section.

• Review and update Tactical Response Plans (TRP).

• Ensure sufficient Oil Spill Removal Organization (OSRO) subject-matter experts in exercise control and the Incident Command Post to add to realism and assist in response management.

• Update the exercise design guide.

• Continue to make improvements to, and acquire additional, tactical equipment.

• Provide additional open-water boat training.

2015 E3RT Exercise Improvement Plan

The following recommendations were made as a result of lessons learned and successes observed:

Number 01

Lesson Learned Continue ICS role-specific training and encourage involvement of non-operations functions in exercises outside E3RT.

Recommendation ICS role-specific training has proven to be a success. Training should be continued, and expanded to include WebIAP and JETTY software training for targeted personnel.

Number 02

Lesson Learned Expand E3RT staffing.

Recommendation Staffing for section-specific positions is adequate, but additional administrative support should be established for each section and command staff position.

Number 03

Lesson Learned Review and update Tactical Response Plan (TRPs) and Incident Action Plan (IAP) templates.

Recommendation The TRP tactical assignments contain safety information, but should be reviewed and strengthened to further emphasize working safely. This information should be pre-populated within IAP software for easy access and application across all Enbridge plans.

Number 04

Lesson Learned Ensure sufficient OSRO subject-matter expert support.

Recommendation The primary OSRO for the area provided support in the Incident Command Post, but more OSRO staff were required. OSROs should be engaged early in the planning process to ensure they are prepared to provide support in the planning and operations sections, as well as in the Truth Cell.

Number 05

Lesson Learned Update exercise design guide.

Recommendation Update exercise design guide.

Learnings (continued)

9Learnings (continued)

Number 06

Lesson Learned Engage local agencies early during exercise design and planning.

Recommendation Continue to engage local agencies early during exercise design and planning, confirming with regulators and federal, state, tribal and local partners to identify early representation of all appropriate organizations. This should also be reflected in the Exercise Design Guide.

Number 07

Lesson Learned Initiate early dialogue with tribal leaders during exercise planning phase.

Recommendation Continue to engage tribal leaders during exercise design and planning. Confirm if individual tribes and/or their association should be part of exercise planning. This should also be reflected in the Exercise Design Guide.

Number 08

Lesson Learned Conduct ICS 201 workshops for kickoff of proactive phase exercises.

Recommendation Continue to use the ICS 201 workshops as kickoff for all future proactive-phase, large-scale exercises. This should also be reflected in the Exercise Design Guide.

Resources

Numerous types of equipment, resources and documents were deployed or simulated to support the tactical operations identified during the exercise planning process. No gaps were identified during the Exercise Tactical Planning/Ordering Process. Listed below are the significant pieces of equipment and resources used during tactical deployment:

Tactical Response Equipment Deployed

• 4900 ft of boom

• 4 skimmers

• 12 small boats

• 8 USCG vessels

• 4 pumps

• 2 vacuum trucks

Response Support Documents and Systems

• Integrated Contingency Plan (ICP)

• Tactical Response Plan (TRP)

• Health and Safety Plan (HASP)

• Incident Action Plan (IAP) Software

• JETTY Software

• Viper Air Monitoring Software and ProRAE Guardian System

• Incident Management Handbook

U.S. Coast Guard conducts an open water response.

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With an inclusive design and planning process, effective resource management and completion of tactical objectives, the E3RT exercise in the Straits of Mackinac was deemed successful by its participants and received considerable praise from attending and observing regulatory agencies and stakeholders. Several lessons learned from the September 2014 Indian River exercise, including the ICS 201 workshop and early

Conclusion

engagement of the local agencies and area tribal representatives, were specific areas of focus for the exercise design team; implementation of these elements resulted in a stronger, more effective exercise. The lessons learned from this exercise will be reviewed and applied to future exercises, shared internally across Enbridge to ensure the continued strengthening of Enbridge’s emergency response program, as well as externally with industry peers.

U.S. Coast Guard “Alder” and Michigan State Police conduct open water containment and recovery.

11Appendix A: Participants

Below is the list of attending exercise design members, players, observers, and visitors by their agency, company or organization’s name.

Name

Design

Team

Exercise

Player

Observer/

Visitor

Enbridge X X

U.S. Coast Guard (USCG) X X X

U.S. Environmental Protection Agency (EPA) X X X

U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA)

X X X

U.S. Fish and Wildlife Service (FWS) X

U.S. National Weather Service (NWS) X

U.S. National Oceanic & Atmospheric Administration (NOAA) X

Canadian National Energy Board (NEB) X

Michigan Department of Environmental Quality (DEQ) X X

Michigan State Police (MSP) X X

Michigan Department of Natural Resources (DNR) X

Michigan Department of Health & Human Services X

Michigan National Guard X

Sault Tribe of Chippewa Indians X

Wekwemkoong Unceded Territory X

Little River Band of Ottawa Indians X

Saginaw Chippewa Indian Tribe X X X

Chippewa Ottawa Resource Authority (CORA) X

Mackinac County Emergency Management X X

Mackinac Bridge Authority X

Charlevoix-Cheboygan-Emmet Tri-County Office of Emergency Management X X

St. Ignace Police Department X

Mackinac County Sheriff X

Mackinac County Fire Department X

Cheboygan Life Support Systems X

Mackinaw Marine Rescue X X

Marine Pollution Control (MPC) X X X

Tri-State Wildlife X

Mannik & Smith Group X X

Emergency Management Services International (EMSI) X

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Name

Design

Team

Exercise

Player

Observer/

Visitor

Phillips 66 X

Qualitec X

Tip of the Mitt Watershed Council X

Michigan Public Service Commission X

Michigan Operating Engineers X

St. Ignace Downtown Development Authority X

Hudson Township X

Associated Petroleum Council of Michigan X

Consulate General of Canada X

Residents of Bois Blanc Island X

51 ST CSVT X

Michigan Tech University X

U.S. Customs and Border Protection X

International Joint Commission X

Appendix A: Participants (continued)

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