Compliance Verification Activity Report: CV2223-117 - Trans Mountain Pipeline ULC


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-117
Start date: 2022-04-21
End date: 2022-04-21


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 which will include the Kamloops Fire Department.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Kamloops Tank - Fire Response Exercise

Date & time of visit: 2022-04-21 13:00

Discipline: Emergency Management




On April 21, 2022, a Canada Energy regulator (CER) Inspection Officer and an Indigenous Advisory Monitoring Committee Indigenous Monitor (IM) attended Trans Mountain’s (TM) fire response exercise at its Kamloops Station. The Kamloops fire department (KFD) were also present and used the exercise as an opportunity to familiarize themselves with the site lay out and the processes that Trans Mountain would follow to respond to a similar event.

The exercise simulated a flange fire on tank 61, with the product being a synthetic crude. Responding staff simulated fire response actions at the tank, and an ICP that was established in the facility’s meeting room. The stated objectives for the exercise were to:

This exercise was also designed to assess the accuracy of the Kamloops Station Three-Dimensional Fire Tactical Workbook.

Trans Mountain had firefighting contractors in attendance to provide site specific firefighting information to the KFD. These contractors also discussed any access points and safety considerations the KFD may need in the event of an incident on site.

The exercise began at 13:00 PDT with a safety discussion. This discussion included Covid precautions as well as information on potential hydrogen sulfide (H2S) exposures on site, different facility alarms which may be heard and muster areas. Additional safety considerations included how vehicles may present an ignition hazard depending on location, slips trips and falls, automated external defibrillator locations, first aid rooms on site, and location of both overhead and underground utilities. A safety data sheet of the synthetic crude was available to participants and hot, warm and cold zones were established. A 60 meter area was set for the hot zone and 90 meters was set for the warm zone as per Trans Mountain’s tactical workbook.  The safety meeting was conducted efficiently and covered relevant safety topics.

At the release site, air monitoring was simulated via personal monitors with levels of zero being recorded for H2S, Benzene and lower explosive limits (LELs). Trans Mountain’s responders who entered the hot zone wore self-contained breathing apparatus as would be required in a real event. TM staff confirmed a simulated fire at 13:04 PDT. Trans Mountain staff then established this incident as a level 3 emergency, consistent with Trans Mountain’s Emergency Response Plan. Trans Mountain staff in the incident command post began developing an Incident Command System 201 Incident Briefing form and the organization chart and appropriately staffed the necessary positions. Trans Mountain staff also produced a site map which was used to determine access to the incident, and which assisted in establishing the hot and warm zones. At 13:13 Trans Mountain staff on their internal call down list confirmed they had received confirmation of a simulated incident via their internal communication system, an example of the notification received on staff phones was shared with the CER.

During the above activities, the fire response contractors worked in the hot zone, providing information to the Kamloops Fire Department on the hydrant location and different considerations on firefighting options at this site. At 13:32 PDT the foam trailer was on site and staff began active firefighting efforts. Trans Mountain staff used the on-site fire response equipment to first apply water to the simulated fire and then connected the water hose to their foam containers which would escalate fire response efforts. Trans Mountain staff continued to monitor air quality and confirmed zero levels of H2S, LEL, and Carbon Monoxide. At 13:55 PDT water was flowing onto the simulated fire, and the exercise concluded at 14:03 PDT.

An exercise debrief was conducted and exercise participants were given an opportunity to provide feedback. Participants discussed feeling better prepared to respond to a similar incident and expressed appreciation for having gotten more familiar with equipment on site due to this event. Trans Mountain staff also noted the benefits to having Kamloops Fire Department on site to work with them. This feedback was collected and will be used to inform future exercises and continuous improvement of responses procedures.

The Objectives for the exercise were met as Trans Mountain’s staff had worked through a site safety plan, tested their on-site equipment and referred to their response plan to ensure a safe response. It was noted that Trans Mountain’s staff worked well together, and that equipment was delivered to the impacted site very quickly. This allowed the fire response contractors to take time to discuss response options with the Kamloops Fire Department for their ongoing improvement of emergency response efforts with partner agencies.

Trans Mountain staff displayed their ability to respond to this scenario, and no non-compliances were observed.   

Note that the IM Observation attached refers to a matter that is not related to this activity. It is recorded here but will be addressed through the CER's Issues Management Process. 


Compliance tool used: No compliance tool used

Observation 2 - Indigenous Monitor Observation - [Whispering Pines] Condition Compliance

Date & time of visit: 2022-07-18 12:12

Discipline: Indigenous Monitoring




The most recent condition #117 filling from 2020, TMX asserts the terminology “an update at least 1 year prior to the commencement of operations.” in contrast to the specific text of all the other historical submission/documents for Condition #117.

Reference material:
The documents on condition #117 “The text of Condition 117, as established by the Board” is.

“Trans Mountain must file with the NEB, at least 2 years and 1 year prior to commencing operations, detailed updates for the company’s review of its Emergency Management Program (toward meeting the requirements of Condition 124). This filing must include: (a) (b) (c) a summary of work undertaken to-date; the approximate timing for completing remaining work; and a summary of parties that were consulted (Condition 90) and how their comments and feedback were considered in improving the program.”     (

“The next filing for this condition is expected one year prior to the commencement of operations (approximately August 2018). The NEB will review the filing and compare it to the 15 June 2017 filing to ensure that the company has continued to collect stakeholder, Aboriginal community, and landowner feedback and input as well as document and consider the input in enhancing Trans Mountain’s Emergency Management Program. “ ( )

This document section 4.0 CONCLUSION = “Further to this, NEB Condition 117 mandates two filings; the first at two years prior to operations and the second at one year prior to operations.  The subsequent filing to this first report will provide detail on the additional enhancements to the EM Program.  Other NEB Condition reports relating to emergency management must also be filed and work to address specific enhancements which will be completed over the remainder of this Consultation 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