Compliance Verification Activity Report: CV2223-094 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV2223-094
Start date: 2022-05-09
End date: 2022-05-12


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

Process Safety at Trans Mountain Edmonton Terminal - Evaluate the implementation and close-out status of  HAZOP action items; TMEP Asset turnover, including pre-commissioning, commissioning, pre-startup safety reviews, and Management of Change for startup operations; Assessing completion of preventive maintenance (inspection and testing) activities on safety systems and safeguards (i.e., pressure-relieving devices; emergency, fire, gas and release protection systems; sensors, alarms and interlocks) per prescribed frequencies under CSA Z662 and company programs.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - TMEP HAZOP

Date & time of visit: 2022-05-10 09:00

Discipline: Safety Management




Trans Mountain (herein referred to as "TM") conducted a Hazard and Operability Study (HAZOP) for the Edmonton Terminal as part of the TM Expansion Project (TMEP) for the purpose of identifying and addressing new hazards associated with the project. Items within the HAZOP were reviewed with the CER inspection team which included a register used to track the status of HAZOP recommendations.

TM stated that TMEP Engineering and TM Operations are responsible for the implementation of the HAZOP recommendations. TM also stated that items are not considered closed until operating procedures (if required) have been developed and/or operational documents have been updated to reflect the implemented items.

The inspection team noted that TM's HAZOP tracking/resolution log used the term "Complete" or "Closed" for items where action items have been developed but the recommendation has yet to be implemented/executed. The team informed TM that it should consider revising its terminology on the log given that the "Complete" or "Closed" status for such items implies implementation and execution have been conducted.

Compliance tool used: No compliance tool used

Observation 2 - TMEP Asset Turnover

Date & time of visit: 2022-05-11 09:00

Discipline: Safety Management




Trans Mountain (herein referred to as TM) stated that over the course of the Expansion Project (herein referred to as TMEP) TM's Operations maintain continuous communication and interface with the TMEP team and its general contractor(s) (herein referred to as GCC). TMEP stated that the asset turnover includes but is not limited to:

The CER inspection team reviewed the asset turnover process and supporting documentation for the Delivery Manifold Area (DMA) which was granted Leave to Open by the Commission on April 11, 2022. The process and documentation appeared complete. However, the team notes that housekeeping items such as debris, absence of caps on open drains, etc. in the DMA should be addressed

Compliance tool used: No compliance tool used

Observation 3 - Signage - Pumphouse

Date & time of visit: 2022-05-11 15:30

Discipline: Safety Management




No H2S warning sign was present on the entrance to and inside the pump-house building. 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall post  H2S warning signage at the pump house.

Due date: 2022-06-13

Date closed: 2022-07-19
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 4 - Indigenous Monitor Observations

Date & time of visit: 2022-05-11 16:00

Discipline: Indigenous Monitoring




Indigenous Monitor Observation Report CV 2223-094

Jonathan Wright – Sucker Creek First Nations Indigenous Monitor

May 10th to 11th, 2022



CER – Canadian Energy Regulator

IM – indigenous Monitor

IR – Information Request

NNC- notice of Non-Compliance

CNC- Corrected Non-Compliance

FN – First Nations

TLU – Traditional Land Use

HDD – Horizontal Directional Drill

DTA – Department of Transportation of Alberta

KP – Kilometre Point



The inspection took place on May 10th & 11th at the Sherwood Park terminal in Sherwood Park, Alberta. Was attended by a Sucker Creek Indigenous monitor and three CER inspection officers. We investigated the safety of the terminal and its workers.


All safety related inquiries and observations are the same as made by the CER inspection officers and I have no other observations to add safety wise.


Observations/inspection: tributary to North Saskatchewan and remote impoundment.

We look at the leak detection methods, protocols, spill ways, manholes and remote impoundment valves. Also look into migratory bird mitigations and protection measures.






· Identified by operations that their hydrocarbon detector is also installed on the intake from pipeline alley to the trib. To the North Sask. So that if there is a release upstream from another facility, they are able to detect it and divert the flow to their remote impoundment as an extra protection measure.

· We inspected the intake valves to the remote impoundment and noted that all valves have hydrocarbon detectors in place and are on an automatic shutoff if detected. Also observed that all valves are locked in place with the LOTO tag system to ensure that no accidental or unnotified swinging of valves would occur. Also noted that only operations are allowed to swing valves.

· Was also informed by operations that intake valve from other companies is locked shut and all water to be placed into their remote impoundment must be tested prior.

· The lining of the remote impoundment is also inspected regularly by operations and a third party by request to ensure its integrity is maintained and no chance of accidental release of water in the ground.

· All water in tested by third party prior to any release to the tributary. Water is first tested by third party; a field test is administered by operations and a visual inspection in conducted before any release is conducted. Also, there is a hydrocarbon detector on the outtake valve as an extra security measure.

· Noted some migratory birds were in pond, not a regular occurrence, no hazard was present for birds, migratory act was known by operations and was indicated to me that normally remote impoundment water level is kept low to ensure fowls don’t use pond as a hub.

· Noted that some safety signage was down around remote impoundment, indicated that it was down due to winter snow removal maintenance or spring thaw. Operations noted the sign down, which was still visible just not in a fixed position and will rectify as soon as possible – no enforcement tools issued.

· Also indicated by operations that the remote impoundment is capable of holding the volume of one 400,000 bbl tank and 10% of the volume of the other 24 tanks on the east tank farm and a 100 flood event.



· Was very impressed with the overall attention to leak and hydrocarbon detection measures and protocols in place to ensure noncontaminated water enters the tributary.

· Possible add signage down to deficiency list so it is not put on the back burner and forgotten about.






Observations/Inspection: erosion control measures at drainages in the facility

While walking the grounds during the inspection we stopped to inspect erosion control measures of the drainage ditches around the tank farm and ones that go towards the remote impoundment.



While inspecting facility and remote impoundment was able to have a detailed look at the improved erosion control measures in place around the tank farms and around the remote impoundment. Please note that the new measures in place are a great improvement that those indicated in the 2019 CVA. Was very pleased to see the improvements in place.



Add erosion control measures to operations checklist if not already to ensure continued integrity and performance especially after heavy rain events or tank releases.



I found it to be a very informative and great inspection. The TMX construction staff and operations staff were very helpful, informative and friendly. I have no issues to note on this inspection and hope that you continue the great work that is being down at the facility.

I look forward to the next inspection and the continued partnership between TMX and the IAMC.



Jonathan Wright

Sucker Creek Indigenous Monitor

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