Compliance Verification Activity Report: CV2122-086 - Trans Mountain Pipeline ULC


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-086
Start date: 2021-06-15
End date: 2021-06-15


Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):


Rationale and scope:

Verify response capabilities during TMPU's fire deployment drill at the Sumas Tank Farm on 15 June 2021. The drill will include local authorities.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Sumas Fire Response

Date & time of visit: 2021-07-15 12:00

Discipline: Emergency Management




A Canada Energy Regulator Inspection Officer and an Indigenous Monitor from the Indigenous Advisory Monitoring Committee attended Trans Mountain’s full surface tank fire drill on June 15th, 2021. The exercise was held at the Sumas Tank Farm in Abbotsford B.C. and simulated a full-surface tank fire involving tank 121.
The exercise objectives were:
                1. Conduct a detailed safety briefing prior to deploying fire equipment
                2. Safe use of Sumas Tank Farm firefighting equipment 
                3. Verify the Sumas Tank Farm Fire Pre-Plan and onsite tactical workbooks

Response Management
The exercise started at 12:32 with a briefing on the scenario, a simulated hand off between the current incident commander and the incoming incident commander, and a review of the objectives for the exercise. These objectives were included in the Exercise Plan, sent prior to the exercise. The exercise briefing was directed to the on-site staff and the firefighters contracted to Trans Mountain for fire scenarios at their facilities. 

The response team consisted of the incident commander, a safety watch, and the contracted firefighters who carried out the simulated fire response. It also included Trans Mountain staff operating the water-cannon’s water pump. The incident commander provided a thorough incident briefing which included an overview of potential fume issues, locations of windsocks, H2S concerns and a review of the Safety Data Sheet information on Cold Lake Crude oil which was the product in the tank. The incident commander also outlined the amount of product in the tank and the remaining tank volume. This information was used for calculating boil over time, and the amount of firefighting foam and water that could be added to the tank safely.

The briefing also included safety issues such as heat exposure, lifting hazards, slips, trips, and falls and COVID-19 precautions. Exercise participants wore 4 gas meters to monitor potential threats from vapors. The current readings were shared at this time (0 parts per million). All air quality results were simulated only.  Sumas Tank Farm is an active construction site, so safety relating to additional personnel and traffic on site was included.  

Other scenarios such as air monitoring, off-site impacts, and notifications were simulated only and were not part of the scope of this exercise.

Hot, warm, and cold zones were established as well as the personal protective equipment requirements of each zone, and the position of the water cannon was discussed. For this exercise a tarp was laid on the hill side to act as a target for the water cannon, rather than putting water onto tank 121. This was to avoid introducing water into the storage tank. The tarp also served to prevent erosion impacts from the water that would be used for the exercise. The distance from the cannon to the tarp was equal to the distance the cannon would have to reach to properly control a fire on tank 121. The locations where the water cannon should be placed are predetermined for responding to fire incidents. These locations are part of the site’s Fire Pre-Plan and are part of Tran Mountain’s ongoing site safety efforts for their tank farms. The cannon locations for each tank are based on safety assessments and consider access to a location, potential distance the cannon may have to reach, public safety concerns and wind directions.

The Trans Mountain Incident Commander posted a map of the facility with the hot, warm, and cold zones marked on it, as well as an Incident Briefing form (ICS 201), and the workflow chart for fire response. These reference materials, and the Sumas Fire Pre-Plan, were available at the command post on site.

After the initial briefing ended the firefighters began the work of connecting hoses, readying the water cannon, and getting it into proper position for the exercise. At 13:16 the hoses were connected to the water cannon, and water was deployed successfully from the water cannon at 13:28. Crews worked efficiently to flow water. The firefighters each worked the cannon for familiarity with the device and learning the nuances of the site’s layout and the associated equipment.

At 13:52 the exercise was concluded with the objectives having been met. CER staff noted that there were no non-compliances.

Exercise participants communicated via radio. The incident commander, the firefighters and those operating the pump communicated to coordinate the flow rate of water. Exercise participants noted that during the operating of the pump and the water cannon it could be difficult to hear the handheld radios, and dedicated headsets were suggested as a potential option to increase clarity of incoming messages.

COVID-19 Safety
COVID-19 precautions included social distancing and the use of masks. All attendees were also required to fill out the COVID-19 self-declaration form, as indicated in the Trans Mountain COVID-19 Self Declaration and Guidance, to be produced on request. CER staff noted that throughout the day exercise attendees wore masks and socially distanced where it was required to do so. The COVID-19 efforts conformed with BC requirements.
The team of contractors and Trans Mountain staff worked well together and their efficiency and attention to safety were noted.  Once the response objectives had been met the exercise participants offered thoughts on what went well with the exercise and areas for focus on future exercises. One noted suggestion, found above, was for headsets to be offered for staff working the pump, due to the noise levels. Trans Mountain staff recorded all suggestions from the discussion at the close of the drill in order to review and determine what improvements can be implemented in the future. 

The attending Indigenous Monitor reviewed this report and did not have additional comments to add.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to:

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program