Compliance Verification Activity Report: CV1920-460 - TransCanada PipeLines Limited


Compliance verification activity type: Emergency Response Exercise

Activity #: CV1920-460
Start date: 2019-10-01
End date: 2019-12-31


Regulated company: TransCanada PipeLines Limited

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):


Rationale and scope:

As part of the CER's annual compliance planning, TC Energy was identified for an exercise evaluation to verify the company's response capabilities during an emergency response exercise. The exercise is a TTX for its Gas Control Centre, that covers their Foothills System and Main Line.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Exercise evaluation

Date & time of visit: 2019-10-11 09:00

Discipline: Emergency Management




Exercise Planning and Conduct
An Emergency Management Exercise Evaluation Team of the Canada Energy Regulator (CER) attended a table top exercise hosted by TC Energy in Calgary AB, 11 October 2019. The team consisted of an Inspection Officer (the Officer) and an Emergency Management Specialist (the Specialist). The exercise was conducted to meet the company’s requirement demonstrating compliance to s.32 of the Onshore Pipeline Regulations and Clause 10 of CSA Z662-19. A Situation Manual and Exercise Plan were available and shared with the CER before and during the exercise, and a debrief report was provided post-exercise. Other attendees included company participants and facilitators.
TC Energy’s Gas Control Centre can house several specific Control teams that operate various portions of its facilities. The purpose of this exercise was part of Gas Control’s annual quality assurance activities, and was developed to assess TC Energy’s Gas Control team’s effectiveness during an emergency response procedure on the Central portion of its system.  The exercise objectives included having Central controllers recognize and diagnose potential emergencies, to describe actions required in the event of an actual emergency, and to practice using control room documentation and supervisory control and data acquisition (SCADA) schematics.
The Evaluation team verified that Emergency processes and procedures were utilized during the training exercise.  The documents followed by company staff covered safety, communications, and system operation procedures for use during emergencies. These pre-developed procedures allowed simulated first responders and members of Gas Control to have consistent and applicable procedures to rely on for various situations they may encounter while operating TC Energy assets. 
Calgary Gas Control switched over operations to the backup system and location for the duration of the exercise. This was done to not only allow exercise participants an undistracted training environment, but to also test the functionality of the operational transfer and backup control system itself.
Notification and Reporting

External notifications were not part of the scope of this exercise.  It was discussed that the Corporate EOC would have completed the notification of outside stakeholders, such as the TSB and CER, if the EOC was activated for the exercise.   
Internal notifications were accomplished as prescribed in the appropriate company manuals, see section below on Communications. 
Safety of participants was discussed at the beginning of the exercise. Alarms, muster points and exits were explained by the facilitator. As this was an office based exercise, no PPE or related field safety equipment was required. Since the exercise was conducted during Mental Health week, the safety moment outlined some potential causes and effects of mental illnesses.
The simulated response was focused on preventing a larger incident and the focus on public safety was a priority.
Response Management
At the onset of the incident, the Gas Control Operations staff activated the Alberta, Foothills and Canadian Mainline System H2S Mitigation Procedures. These pre-determined processes and procedures which responders followed, provided a detailed method as to the tracking, isolating, and blending of the high H2S concentrated gas. These procedures also included how to calculate the flow of gas within the pipeline and dilution needed to prevent further stress to system integrity.
An effective organizational structure which paralleled the normal Gas Control structure was used for the duration of the incident response. The use of the structure allowed for an effective and streamlined response effort, as each exercise participant knew their role at the onset of the emergency.
A process for the internal reporting, analysis, and investigation of the anomaly were reported through the Central Controller as well as to the field where technicians were dispatched to investigate and support response efforts.

Although not stood up during this training exercise, discussions took place regarding the activation of the Corporate Emergency Operations Center (EOC) and how the presence of a senior Gas Control member within the EOC would have contributed to the response. This organizational structure allows Gas Control to have a representative within an activated EOC to share vital situational information.

CER Staff observed that the company’s Gas Control Operations staff ensured the pipeline control system was being effectively operated and monitored. CER Staff also noted that Gas Control Operations Staff carried out their emergency management responsibilities in accordance with company processes and procedures. TC Energy staff also demonstrated that the response measures implemented were suitable in controlling and managing the incident. Gas Control staff implemented a process for coordinating and controlling the various operational activities within the control room, this also contributed positively to the management of the incident.

Response Tactics

When the Control Room noted a sharp increase in H2S levels within the system, Operational Staff immediately began to implement mitigation outlined within the company’s Alberta, Foothills and Canadian Mainline System H2S Mitigation Procedures. This included calculations of gas flow and concentrations and estimated times that the product would arrive at downstream facilities.

TC Energy Central Control Operators utilized on-site schematics in conjunction with the SCADA systems. Utilization of the paper schematics allowed for responders to look at a much larger section of the system at one time. While utilizing these schematics, it was noted that the legend and actual distance measurements were not the same. The legend indicated that all measurements were in kilometers, however they were actually in meters. This was noted by the operators and will be corrected on the next update of the schematics.

Measures taken by Central Control during the incident included:

 Central Control staff, utilizing the TC Energy response manuals and their individual experience, were precise and effective while initiating the measures indicated above. Clear communication and response expectations were laid out early in the response which created an environment within the Control Room resulting in an effective response. The Incident Commander (IC) located within the control room tasked teams to work on slug speed -  estimating the time it would reach lateral lines and downstream assets; blending tactics; external communications; and system supply impacts for downstream customers.

During the response, Gas Control received multiple calls from protesters and media. Aggressive and confrontational protester calls prompted responders to activate their security procedures. The calls were addressed in a professional manner and any pertinent information was passed up the chain of command and eventually to the RCMP [simulated]. The media call received was immediately deferred to the Public Information Officer. Despite the consistent push for information by the media caller, members of the Gas Control staff remained professional and patient and continued to reiterate they contact the Public Information Officer. The required policies and contact numbers required for each of these situations were readily accessible within the Control Room. 

Overall, CER Staff observed Gas Control staff managing the emergency situation from start to finish in a technically and professionally sound manner. The clear delegation of tasks as well as a pre-defined and effective means of communication, allowed Gas Control staff to detect, communicate and resolve all aspects of the emergency.


TC Energy’s Control Room staff activated the Emergency Response procedures and simulated bringing in supporting corporate resources to handle external communications and coordination of information to the public.
Internal notifications procedures were activated as well. A portion of the simulated exercise involved coordination of communication between separate Control Room teams and additional company integrity engineering personnel.   
Post Exercise
Overall, CER Staff are of the view the table top exercise objectives were met. The training completed was in line with a functional exercise. The participants were not completing a walk through or a talk through of what they would be doing as it relates to the exercise scenario, rather, exercise participants played out the appropriate processes and procedures as if it was a real incident.
CER Staff note that the 3 hour table top exercise was, realistic, process driven and effectively accomplished all objectives set forth by the facilitators. The response structure implemented by Gas Control was the same structure used for normal operations and effectively tested Control Room staff response capabilities.
CER Staff observed responders implementing the appropriate emergency procedures for the exercise. CER Staff also observed responders documenting their actions either on paper or on whiteboards used as an ICS 214a unit log, located throughout the control room.  Keeping accurate activity logs is a vital aspect of emergency management as they could become legal documents for a prolonged or more severe event.

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