Compliance Verification Activity Report: CV2021-236 - Trans Mountain Pipeline ULC


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-236
Start date: 2021-03-04
End date: 2021-03-04


Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):


Rationale and scope:

As part of the continual monitoring of TMPU's response capabilities, CER will evaluate a CER unannounced exercise (conditioned as part of Trans Mountain's audit on fire response and preparedness) related to the company's fire response and preparedness at the Burnaby Terminal.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Emergency Management

Date & time of visit: 2021-03-04 16:10

Discipline: Emergency Management




Background/Scope of Activity:
On 4 March 2021 at 16:10 PST, the Canada Energy Regulator (CER) initiated an unannounced exercise to simulate a response to a full surface crude oil tank fire at the TMPU Burnaby Terminal. The unannounced exercise was conducted in order for TMPU to fulfill the requirement detailed in the Trans Mountain Pipeline ULC (TMPU) Addendum Final Audit Report – Emergency Management (EM) Program, Fire Preparedness Planning of 31 May 2019. The requirement was for TMPU to respond to a CER fire response unannounced exercise at a time and location of the CER’s choosing within 12 months of TMPU establishing and integrating a four (4) hour response target, as described in the addendum letter:
For its Burnaby and Edmonton Terminals, TMPU must establish and integrate into all fire plans and associated planning and preparedness activities, a four (4) hour response target time to initiate extinguishment of a full surface tank fire for the largest tank at each facility.
Trans Mountain had to demonstrate that it could get the needed personnel and equipment on site and ready to extinguish a fire within four hours. This timeframe is intended to mitigate potential boil over from the tank itself. The exercise was timed to coincide with the start of rush hour traffic in the Lower Mainland as well as early evening light conditions in order to add an additional level of complexity. An unintentional complexity adding to the scenario was the rainy weather experienced during the exercise.
CER Evaluation:
Two CER staff members and one Indigenous monitor attended the exercise to observe and evaluate.
Response Management
1. CER staff observed:

2. The following key observations were made by CER staff:

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