Compliance Verification Activity Report: CV2122-003 - Trans Mountain Pipeline ULC


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-003
Start date: 2021-04-06
End date: 2021-04-07


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

Verify response capabilities during TMPU's Westridge Terminal Full Scale exercise scheduled 6 & 7 April 2021. This is a multi-jurisdictional exercise. The exercise will include the establishment of the Incident Command Post (in-person and virtual via MS Teams) with a field deployment. The annual deployment of the secondary containment boom will occur in conjunction with the field response. This exercise is being held in order to meet Canada Shipping Act (CSA) requirements. It is NOT focused on CERA or the OPR. However, the response processes and plans are essentially the same for a response under the CSA or the CERA. Thus, CER staff will evaluate this exercise as a CVA to assess the company's readiness and ability to respond to an incident under CER legislation. The scenario for this exercise will involve a failure of the loading arm resulting in a release of approximately 100m3 of Access Western Blend (AWB) into the Burrard Inlet during ship loading operations. Because there is a vessel attached at the dock and transfer of oil is underway, the Canadian Coast Guard (CCG) is the lead federal response agency as per our 2015 Letter of Agreement with CCG. The CER still retains its regulatory responsibilities and have had discussions with CCG on how the CER will participate in the exercise. CER staff will play a technical specialist role directly to Unified Command. The objectives for this exercise have been separated into both Incident Command Post (ICP) and Field Deployment, as set-out below. ICP Objectives • Establish a functioning ICP supported by in-person and virtual responders appropriate for the exercise scenario • Implement the Incident Command System (ICS) Planning Cycle through to successful completion of the Tactics Meeting • Develop a communications plan for communicating with internal company stakeholders • Develop an incident specific executive briefing package for Trans Mountain senior leadership • Develop the following incident-specific supplemental plans o Non-Floating Oil Plan o Waste Management (disposal) o Indigenous Community Relations Plan (Liaison Office) • Test Trans Mountain/Western Canada Marine Response Corporation (WCMRC) operational mapping and on-water tracking capabilities for released oil • Establish an effective documentation control procedure capable of compiling all paper-based and virtually produced incident records • Develop and maintain a common operating picture capable of providing situational awareness to both in-person and virtual responders Field Deployment Objectives • Confirmation of emergency shutdown procedure for Westridge loading arm during transfer operations • Confirm ship to shore communications procedures via radio with Trans Mountain Loading Master • Placement of secondary containment boom within 1 hour of field deployment exercise start • Develop an Initial Site Health & Safety Plan for onsite responders • Identify Hot/Warm/Cold Zones and establish an effective onshore decontamination setup • Demonstrate effective radio communications among response vessels and shoreline operations

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Westridge Marine Terminal Full Scale Exercise

Date & time of visit: 2021-04-07 09:00

Discipline: Emergency Management




Trans Mountain (TM) initiated the Westridge Marine Terminal exercise on April 7, 2021. As this was a full-scale exercise it included both an on-water deployment of vessels at the terminal and an Incident Command Post (ICP) at a separate location. There were also multiple agencies involved that have jurisdiction or interest in the scenario. This meets TM’s definition of a full-scale exercise.

The exercise was attended by three Canada Energy Regulator (CER) staff and two Indigenous Monitors (IM) from the Indigenous Advisory Monitoring Committee (IAMC). Other attending agencies include the BC Ministry of Environment and Climate Change (virtually) Environment and Climate Change Canada (virtually), Transport Canada, Canadian Coast Guard, Fisheries and Oceans Canada (virtually), Canadian Wildlife Service (virtually), Vancouver Fraser Port Authority (virtually) and Western Canadian Marine response Corporation (WCMRC). Witt O’Brien’s was used as a coordinating contractor for the virtual platform and served in a coaching role. The first nations of the Musqueam Indian band and Tsleil-Watuth nation (TFN) also virtually participated.

Exercise Planning and Function
CER staff attended pre-planning meetings and were given access to Trans Mountain’s Microsoft Teams platform. This exercise was also assessed by Transport Canada, as the scenario was designed to meet Trans Mountain’s requirements under the Canada Shipping Act. As such, CER staff did not play a role within Unified Command (UC) or make decisions around response objectives. The Canada Coast Guard played the role of the lead federal agency for responding to the incident. CER staff played an influential within the Unified Command through the role of a Technical Specialist. This allowed for the CER's awareness, interests and technical expertise to be maintained.

The Unified Command was made up of representatives from the Canada Coast Guard, Trans Mountain, BC Ministry of the Environment and Climate Change, TFN and Squamish first nations. Both first nations were joining a Trans Mountain exercise in this capacity for the first time. The number of attendees at both the ICP and in the field were limited to 50 due to provincial health mandates.

The exercise was initiated with a handover from the previous Incident Commander (IC) to the incoming IC. The exercise simulated a release of 100 m3 of Access Winter Blend (AWB). The Incident Command System (ICS) Form 201 Incident Briefing was reviewed to inform the incoming UC of the latest information. The company designated this incident as a level 3 emergency as it met the criteria within their Emergency Procedures Manual (EPM). 
The objectives for the exercise were:
• Establish a functioning ICP supported by in-person and virtual responders appropriate for the exercise scenario.
• Implement the ICS Planning Cycle through to successful completion of the Tactics Meeting.
• Develop a communications plan for communicating with internal company stakeholders.
• Develop an incident specific executive briefing package for Trans Mountain senior leadership.
• Develop the following incident-specific supplemental plans:
                 o Non-Floating Oil Plan
                o Waste Management (disposal)
                o Indigenous Community Relations Plan (Liaison Office)
• Test Trans Mountain/Western Canada Marine Response Corporation (WCMRC) operational mapping and on-water tracking capabilities for released oil.
• Establish an effective documentation control procedure capable of compiling all paper-based and virtually produced incident records.
• Develop and maintain a common operating picture capable of providing situational awareness to both in-person and virtual responders.
Information flow within the ICP was almost entirely virtual. Trans Mountain staff used the Microsoft Teams platform to communicate, share data, and populate the required ICS forms and reports. During exercise play, Trans Mountain staff reported they were able to effectively contribute to their assignments with staff, even if those staff members were located off site. CER assessors were able to see that Trans Mountain staff were collaborating with multiple other sections and units within the ICS structure.CER staff also noted that Trans Mountain appropriately followed its COVID-19 safety protocols; for example, staff wore masks throughout the day, maintained proper social distancing and had access to hand sanitizers.

Included in the information flow was the maintaining of a common operating picture between the field and ICP. Trans Mountain had arranged for WCMRC to provide on-water updates to the ICP, including mapping through the Geographic Information Systems (GIS) unit. The GIS unit created maps that included information on trajectory modeling from Environment and Climate Change Canada as well as real time information provided from field reports and WCMRC's GIS team. These maps were displayed in the ICP for participants to refer to and were updated throughout the exercise as information or injects came in.

Notification and Reporting
Notifications were simulated only. Trans Mountain produced a list of agencies, communities, and elected officials who would be notified for a real event of this nature. These lists named over 100 individuals, agencies or communities. Among them were appropriate federal and provincial agencies, first nations communities and municipalities as well as individual members of parliament, and municipal officials.

The scenario for this exercise also triggered the involvement of the Greater Vancouver Integrated Response Plan (GVIRP) as per requirements under Transport Canada and Canada Coast Guard's legislation. A coordination call with that group was also discussed.

The exercise day began at the ICP and in the field locations with a safety meeting. Both meetings covered potential safety issues that participants may encounter and included COVID-19 precautions. Throughout the day, CER staff noted these COVID-19 precautions were adhered to by all staff. A safety watch and safety officer were also assigned for the exercise.

Safety plans were developed for both the ICP and the field. A medical plan was also developed which included phone numbers, addresses and map locations of BC Ambulance and hospitals in the area. These plans were noted to be thorough and to contain the information expected of them. CER staff also noted that Trans Mountain had posted the address of the hotel at several spots in the ICP so that ICP attendees would be able to report the address of the hotel to emergency services if needed.

Response Management
As per their EPM, Trans Mountain staff managed this incident using ICS. Staff in the ICP established appropriate ICS roles at set-up different tables. This exercise was heavily reliant on a virtual platform, with ICP staff communicating extensively through Microsoft Teams. This allowed for collaboration of specialists from different locations. The exercise worked through the ICS 'Planning P' up to the completion of a Tactics Meeting. Unified Command used break out rooms and the virtual platform to host their Objectives Meeting.

CER staff noted that, while meetings were generally efficient, during the UC Objectives meeting there was some extraneous discussion pertaining to strategies and tactics that would have been more appropriate for the Planning and Operations Sections to discuss and address. There is often some uncertainty related to the appropriate scope of discussion during the Objectives meeting and CER staff observe that this is an area for Trans Mountain to focus on in the next exercise.

Trans Mountain staff established response Divisions within Burrard Inlet due to the scenario involving oil escaping containment. Cates Park was also immediately recognized as a priority due to Trans Mountain's collaboration with local communities and the area was successfully boomed off. Trans Mountain staff also followed their emergency response plan to successfully place a secondary boom around the vessel. This would add an additional level of protection beyond the permanent boom installed around vessels during product transfer.  

An incident status display board was created within Teams. Documents were uploaded virtually only. The command and general staff meeting was held at 12:00. ICP staff held this meeting in a breakout room where those who attended in person interacted with virtual attendees. CER staff monitored the hotel Wi-Fi strength during the exercise, and noted the participants were able to function effectively even with constant use of video conferencing, though there were times where large files would lag in being transferred.

CER staff in the Environment Unit (EU) noted the benefit of the virtual platforms' ability to allow for expert consultants. This enabled them to produce high-quality plans in a short period of time. The ability for a variety of participants also aided in creating high quality reports, though a potential drawback noted was that as a unit grows, it will be important to ensure there is not an exceedance of the expected span of control. The span of control was not observed to have been exceeded in this exercise. CER staff noted in particular that the ICS 232 Resources at Risk form was developed with a high level of collaboration between the company, affected communities, and partnering agencies.

CER staff observed that the company effectively demonstrated a “get big quick” strategy by ordering and coordinating a significant amount of operational spill response resources from both within and outside of Trans Mountain.   

Trans Mountain developed several detailed plans and outlined the initial drafts of these plans for UC during a Plan Review Meeting. CER staff observed that these plans were very comprehensive and included specific third-party consultant expertise as required. These plans included Community Air Monitoring, Heritage Resources Impact Assessment, Non-Floating Oil, Waste Management, and Indigenous Liaison and Community Relations Plan.


Field to ICP communication was achieved through cell phone, text, email and virtual means. The ICP was observed to be receiving sufficient information from the field to keep the ICP staff informed of progress from the field.

A CER staff member was assigned as a communications officer to the Joint Information Center (JIC). The JIC was made up of numerous company representatives, as well as other Federal representatives from the Canada Coast Guard and WCMRC. Before the exercise began, the company had assigned two main communications objectives for the exercise: to develop a communications plan for effectively communicating with internal company stakeholders (employees and contractors) and developing an incident-specific briefing package for Trans Mountain Senior Leadership.
Like previous full-scale Trans Mountain exercises, company staff occupied all the key roles within the JIC (including Information Officer) and helped gather and process information that was then passed on to the media relations team. That team then created news releases, updates and would inform an afternoon media conference. External agency participants, including CER and Coast Guard were involved in the editing of all joint releases, and provided full opportunity to ensure information was accurate and included sufficient details about the role and composition of the ICP. This collaborative approach allowed the team to produce releases that had the true look and feel of a JIC within a UC (complete with multiple logos at the top), as opposed to purely company-driven communications products.
The biggest bottleneck in communications proved to be getting messaging approved by UC in a timely way. JIC participants were waiting for long periods of time for approved messaging, maps and photos that they could then turn into social media and news updates. In a real incident, this ‘dead air’ would be filled with real-time social media posts, photos and descriptions of the scene from many other sources. Getting information, photos and response plans from the UC into the public domain faster remains one of the key requirements for future communications efforts in EM exercises and real-life situations.
The virtual nature of the exercise likely affected communications in the same ways as other teams and exercise participants. There were many rooms, calls and boards in which to get lost in and incorrectly post information in. These are natural growing pains with a new technology that would be resolved quickly in a multi-day event. The ability to host a virtual command center and link multiple different parties into a JIC is beneficial in many ways, especially in terms of time saved if an incident is in a remote location.

Outside of exercise play, an official media notice was posted to make local communities aware of the exercise so that there would be no public concern with all the activity happening around the facility.

Response Tactics

CER staff and an Indigenous Monitor also attended the field portion of the exercise. For the field portion, the Westridge Terminal Emergency Response Plan and supporting documentation guided response tactics in the field. Tactical training and/or tactical response included:

Health and safety air quality monitoring onshore and on the water included volatile organic compound (VOC) air monitoring and personal gas detector monitoring (LELs, O2, H2S, CO).  Health and safety equipment use included life vests, personal floatation devices, half-mask respirators on water and standard oilfield personal protective equipment (PPE).  COVID-19 precautionary practices included temperature checks, screen questionnaires, enforced used of masks, minimum 2m spacing, hand sanitizer and pre-packaged meals.

As part of the field response Trans Mountain staff deployed a secondary boom around the vessel involved in the scenario, as well as tasked WCMRC to set protection booming around Cates Park, as detailed in the Geographic Response Strategy for this area.

Post Exercise

Immediately following the exercise, Trans Mountain staff debriefed within their work groups to produce short lists of what worked well for them and what areas they would like to see improved on. Most of the feedback revolved around the increased ability to collaborate across distances, the challenge of familiarity with using a new platform, the benefit of a virtual Situation Status board and challenges of those who were remote not feeling fully connected to the efforts that were happening in person. Overall comments regarding the virtual platform were very positive from participants.

As part of the hot wash, UC participants were separated into Command Staff and the various ICS Sections. CER staff highlight the following comments from exercise participants:CER staff noted no non compliances with this exercise.

Indigenous Monitor – ICP Observations 

This IAMC Indigenous Monitor (IM) participated in the ICP aspect of the TM exercise on April 6 & 7, 2021. 

There were representatives from various agencies participating in this exercise “in-person” and virtually in the ICP process; Musqueam Indian Band (MIB) and Tsleil-Watuth Nation (TWN) representatives participated virtually.

This IM attended the exercise in person at the ICP and observed various ICP Section communications through the virtual process. The opportunity to participate virtually appeared to successfully accommodate those participants that could not attend in person and included appropriate Covid protocols. 

IM observations during a portion of a Planning (Environment) Section meeting involved Indigenous representatives from MIB and TWN and discussion/consideration of archaeological protection strategies and prioritization. 

This exercise was a valuable opportunity for TM and other agencies to practice their emergency response process and gather feedback and address any unplanned challenges ie: internet connections, communication process between ICP and In-Field participants, etc. 

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