Compliance Verification Activity Report: CV2122-290 - Trans Mountain Pipeline ULC


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-290
Start date: 2021-07-06
End date: 2021-07-07


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

To verify response capabilities during a spill deployment exercise on the Fraser River on July 6-7, 2021 in Hope, BC at the Telte-Yet Campsite.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Emergency Exercise Evaluation - Sumas District Spill Deployment Exercise

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

Discipline: Emergency Management




Exercise Planning and Conduct
Inspection Officers from the Canada Energy Regulator attended the Trans Mountain Pipeline ULC (Trans Mountain) boom deployment exercise in Hope BC on 7 July, 2021. This exercise was a training drill to familiarize participants with the safe and effective deployment of spill containment equipment as per the company’s Geographic Response Plan (GRP). The deployment was held at the Telte-Yet campground located at 600 Water Ave.  An Indigenous Monitor from the Indigenous Advisory Monitoring Committee was originally to accompany the inspection officers but was ultimately unable to attend the exercise.

Attendees included Trans Mountain’s operational staff, response contractors, the Chawathil First Nation, and the District of Hope Fire Department.  The exercise was held on Chawathil First Nation territory. Trans Mountain had engaged the Chawathil First Nation extensively prior to this exercise to arrange for community members to attend equipment demonstrations and to observe the exercise. This engagement was undertaken at the request of the Chawathil nation in order to better understand the operational aspects of spill response.
Attendees received an Exercise Plan in advance of the event.  This plan stated that the purpose of the exercise was to:

 “…confirm initial spill response capabilities, specifically the safe and effective
deployment of oil spill response equipment within a large volume river system.
The exercise will be used to validate response procedures and deployment
strategies found within the Sumas District Geographic Response Plan…”

The exercise was carried out during high flow conditions within the Fraser River and involved the deployment of boats, boom, a boom vane, and hand lines.  The exercise used a pre-determined control point described in the Trans Mountain Geographic Response Plan (GRP), which was control point 54-12. A safety watch was established for on water and shoreline workers and a designated safety boat was deployed during the entirety of the exercise.

The objectives for the exercise, as identified in the Sumas District Spill Deployment Exercise Plan, were to:
            • Demonstrate the implementation of emergency procedures ensuring the
            safety of personnel by:
                        o Assigning a Safety and Environmental Watch. (Note: The Safety
                        Watch and Environmental Watch can be the same person).
                        o Conducting a JHA which includes a review of the Initial Site Health &
                        Safety Plan with all responders prior to deployment of response equipment.
                        o Conducting boat safety briefing for all crews by each boat captain.
            • Demonstrate the safe deployment of response strategies associated with
            Control Point 54-12 of the Sumas Geographic Response Plan (GRP). Note
            that an alternative deployment strategy may be chosen based on river
            conditions at the time of the exercise.
            • Establish a decontamination corridor using equipment found within the Decon
            Trailer in order to minimize potential contamination a
            • Confirm that oil spill response equipment selected as part of the deployment
            strategy functions as designed.
            • Implement wildlife deterrence equipment to demonstrate the ability to
            discourage wildlife species away from the spill location.
            • Liaise with invited external agencies and indigenous community members to
            enhance understanding of Trans Mountain response capacities within the Sumas region.
After participants and visitors signed in, the exercise day began with an opening prayer from elders of the Chawathil First Nation. As noted above, Trans Mountain engaged with the community to allow for youth and elders to be on-site to observe the exercise. The community had also been invited to equipment demonstrations the previous day. Very positive feedback was provided from the First Nation’s attendees regarding the level of community involvement facilitated by Trans Mountain.

The prayer was followed by the tailgate meeting which consisted of a detailed review of the Job Hazard Assessment and Site Health and Safety plan. This covered safety issues such as slips trips and falls, lifting safely, hazards of working around water, boat safety, security incidents, and fire hazards due to the dry conditions in the area. An airhorn signal of one long blast would be used as a signal to muster at the gate if needed. A Safety Officer was then identified.

The Safety Officer further detailed safety concerns such as rope and cable safety, ropes under tension, pinch points, heat concerns, floating debris, and the personal protective equipment needed for the different areas or tasks being exercised.  

Covid precautions were discussed, including the wearing of masks where participants would not be able to maintain social distancing. In other areas of the exercise masks were not required, which conformed to provincial requirements. All safety discussions were noted as being thorough and well communicated. The concerns referenced in the briefing were all relevant to the exercise. The establishing of the safety officer and safe work procedures also met the objective of “Demonstrate the implementation of emergency procedures ensuring the safety of personnel…”

Response Management
Trans Mountain conducted a detailed overview of exercise objectives and confirmed training expectations to all participants. Following this overview, the designated Incident Commander conducted an operational briefing, delegated response roles, and developed a comprehensive response strategy. The communication plan was discussed identifying the use of cell phones and radios to be used and stressing the requirement to complete a communications test prior to the deployment of vessels.  

The exercise site was divided into a ‘lower area’ near the water’s edge where the exercise participants carried out the exercise requirements, and an ‘upper area’ where the community members could watch the exercise. Hot, warm and cold zones were defined within both the upper and lower areas. The hot zone location was established as the water line and on-water area, the warm zone location was in the ‘lower area’ and included the decontamination area, and the cold zone was the upper area where observers could situate themselves safely. Trans Mountain staff were available in the upper area to explain the exercise and tactics being exercised, as well as to hear the stories and concerns of the Chawathil community members. The engagement of Chawathil observers was highlighted as being beneficial to the community and their understanding of the response processes and was a notable success of this exercise.

After completing all required briefings, Trans Mountain then began the deployment of resources on the Fraser River at control point 54-12. On water operations deployed safety buoys up and down stream of the operational area and shoreline crews set up a decontamination area with wildlife deterrents in the transition area between the hot and cold zones. Trans Mountain water and shoreline teams successfully deployed and anchored the boom to the shoreline. A boom vane was successfully deployed and connected to the boom completing the desired deflection tactic outlined in the GRP. The Incident Commander on the shore was observed explaining all required information and command intentions in a clear and effective manner to supervise the deployment.

The water was very fast through the exercise area that day and the vessels held their positions well and deployed the protection boom efficiently. Throughout the deployment, Inspection Officers noted that boat handling was skillfully done despite the challenging conditions.
In conclusion, Trans Mountain demonstrated that they could successfully and safely deploy boom in high flow conditions. Inspection Officers noted that communication between vessels and onshore workers appeared effective, and the boat operators showed a high level of proficiency to attach and deploy protection boom under challenging conditions. Trans Mountain’s operational staff quickly established a decontamination corridor that was properly attended by decontamination workers who had the necessary tools to allow cleaning of workers or items that may have encountered oil. The visual wildlife deterrents were appropriate, and the efforts used conformed to the GRP at control point 54-12. CER staff notes that Trans Mountain successfully achieved all exercise objectives set out in the Spill Deployment Exercise Plan.

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