Compliance Verification Activity Report: CV1920-463 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV1920-463
Start date: 2019-10-22
End date: 2019-10-24


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

Field inspection of the Edmonton Terminal. Assess compliance to OPR Safety Management requirements.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Safety Observations

Date & time of visit: 2019-10-22 08:00

Discipline: Indigenous Monitoring




CER inspectors and IAMC Monitors received the TMPU Edmonton Terminal specific orientation.  This orientation was very comprehensive and clearly presented.  It included as an example some of the following items:


Compliance tool used: No compliance tool used

Observation 2 - Document review

Date & time of visit: 2019-10-24 08:30

Discipline: Safety Management




- Reviewed Personal Protective Equipment Procedures (PPE)
- Reviewed Noise level Survey documentation
- Reviewed Health & Safety Standards manual

Compliance tool used: No compliance tool used

Observation 3 - IAMC Observations

Date & time of visit: 2019-10-22 14:00

Discipline: Indigenous Monitoring




Indigenous Monitor (IM) #1 Observations:

Trans Mountain Edmonton Terminal:
                          Safety Inspection: October/22/19
 On October 22nd we met with Trans Mountain representatives at the Edmonton Terminal. We met with the Environmental Planner, Health and Safety Advisor and The Manager of the Terminal.
On October 22, CER senior inspector and operations technical specialist did a safety investigation on the terminal.

Indigenous Monitor (IM) #2 Observations:

CER – Canadian Energy Regulator
IR – information request
FN – First Nation
PSV – pressure safety valve
AER – Alberta Energy Regulator
IM – indigenous monitor
TLU – traditional land use
The inspection was completed at the Trans Mountain Edmonton Terminal on October 22nd and October 24th 2019. The inspection was conducted by the Canadian Energy Regulator and by two Indigenous monitors from Alexander First nation and Sucker Creek First Nation.
The focus of the IM monitors is to ensure that during all processes of the Trans Mountain expansion project, and management of existing facilities, that all TLU sites are mitigated properly, all new or missed TLU sites are identified properly and mitigated properly. Also to ensure that all FN concerns are mitigated, addressed and informed upon.
The entire grounds, retention pond, facility and piping was completed.
While inspecting the piping was noted that car seals were not on PSV’s on the piping. The car seals ensure that the PSV is kept in the operable position while giving a visual identification that it has not been tampered with.
An IR was issued by the CER which the Facility will give visual evidence of car seals in place and verify compliance with their new operating procedure. This is a leak mitigation which is an FN concern.
During the inspection of the grounds it was noted that there was some erosion at facility sites where a culvert was present.  The environmental representative onsite stated that an erosion mitigation plan was already in place and being implemented onsite.
An inspection was also completed on the remote impoundment by the IM’s and a CER officer for water and water purity is a heavy concern of FN communities.
During the inspection it was noted that the facilities remote impoundment has a one-million-barrel capacity which is 110% capability of possible containments leading to ensure that all of possible spill material will be contained in the facility. The volume is based on the largest tank capacity in the East Tank Farm added to 10 percent of the working volume of the remaining tanks in the East Tank Farm, added to the surface runoff volume in a 100-year, 24 hour storm event.
When it comes to release of the water in the remote impoundment, the water is first tested for hydrocarbons by trained personnel which all tests are regulated & audited by the AER. It is also to note that visual inspection and chemical tests are completed monthly on the remote impoundment to ensure only pure water is released back into the environment.
It was also stated that the facility has hydrocarbon detectors on all inlet and outlet converts to the facility and if there is any detection than the valve is closed off and diverted to the remote impoundment for containment of the water. The measuring system is inspected regularly and overhauls of the detector occur as per specified scheduled maintenance. This ensures that only clean uncontaminated water is released back into the environment.
We also reviewed the training and competency program for the workforce. Through their new systems (WIMS) all training is tracked and kept up to date.
During the inspection no TLU sites were onsite and no new TLU sites were identified.
No TLU sites were addressed or identified. All FN concerns were mitigated, addressed and concluded. No other concerns were identified during inspection.

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