Compliance Verification Activity Report: CV2223-139 - TransCanada Keystone Pipeline GP Ltd.

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-139
Start date: 2022-10-18
End date: 2022-10-19

Team:

Regulated company: TransCanada Keystone Pipeline GP Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

[Ensure TCE is prepared to respond to an emergency. Verify that response actions are based on the EPM and company procedures (is the company doing what it said it would do); assess whether the EPM and procedures protect the health and safety of the public and responders, property and the environment; determine whether exercise objectives were met; and ensure that no effects or potential effects result from participants’ actions or lack of actions. Full scale exercise on 18 - 19 October 2022 in Saskatchewan which will include external parties.]

On 18-19 October 2022, a Canada Energy Regulator (CER) Emergency Response Exercise Evaluation Team (evaluation team) attended the TC Energy (TCE or the Company) full-scale exercise in Moosomin, Saskatchewan. The exercise was conducted on the Keystone oil pipeline. The evaluation team included 2 CER staff. In addition to evaluating, CER staff also joined Unified Command and participated in the exercise.

TC Energy indicated that the purpose of the exercise was to provide an opportunity to perform and execute current response management concepts and plans. The exercise was focused on command-and-control coordination of the simulated event. The exercise objectives were identified as:
 

  1. Safely and effectively integrate with agency response organizations and manage the incident using incident command system (ICS).
  2. Setting the level of the emergency and communicating to appropriate stakeholders.
  3. Demonstrate use of the Emergency Response Plan (ERP).
  4. Engage contractors and coordinate a safe response to a spill.

The exercise included the following components:
 
  1. Exercise kickoff, initial detection by the Liquid Pipelines Control Centre and notification of first responders.
  2. Activation of a Regional Emergency Operations Centre (REOC) to support initial field response.
  3. REOC transfer of command to the Incident Management Team (IMT) and set up and activation of the mobile Incident Command Post (ICP).
  4. Participation in Unified Command and development of an Incident Action Plan (IAP).


 

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Moosomin, SK - Emergency Response Full Scale Exercise

Date & time of visit: 2022-10-19 08:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

As stated by TCE, the exercise scenario was a third-party line strike, which did not result in any injuries. The Liquid Pipelines Control Centre immediately shut in the impacted pipeline and notified company first responders. When first responders arrived on site it was found that the spill had migrated off site at the Moosomin Pump Station.

CER staff evaluated aspects of the following elements:
 


No non-compliances were identified during this exercise. CER staff’s evaluation of the elements listed above indicated that the company response actions were executed according to the Keystone Pipeline System Emergency Response Plan and supporting emergency management and Incident Action Plan (IAP) job aids.
 

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