Compliance Verification Activity Report: CV2223-119 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-119
Start date: 2022-11-01
End date: 2022-11-01

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

[Verify response capabilities during TMPU's boom deployment drill on 3 November 2022 at the Westridge Marine Terminal.]

Note the exercise dates changed and was instead held on November 1, 2022.

Start time will be 13:00 and will run for 1 hour. Company will be deploying boom around the Westridge marine terminal simulating response to a spill into Burrard inlet.

IM / IO will convene a planning call prior to the exercise to provide details. expected time in th field will be from 1230-4PM

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2022-11-07 13:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

On November 1 2022, a Canada Energy Regulator (CER) emergency response exercise evaluation team and an Indigenous Monitor representing the Indigenous Advisory Monitoring Committee (IAMC) attended the Trans Mountain boom deployment emergency response exercise at Westridge Marine Terminal in Burnaby, British Columbia. The evaluation team included 2 CER Inspection Officers. In addition to Trans Mountain Staff, other attendees included Transport Canada and Trans Mountain’s spill response and safety contractors.

The purpose of the exercise, as found in the Participant’s handbook Section 1.2, was stated as: “This exercise is conducted to refamiliarize Westridge operations staff with the processes and procedures to be implemented following a loading arm incident where product is released and impacts the water adjacent to Pier 61. The primary focus of the exercise will be the completion of internal and external notifications, the deployment of secondary containment boom (utilizing Trans Mountain’s response boat), conducting a detailed safety briefing, and establishing a decontamination layout.”

This was designed to be a training exercise to allow for greater learning and developing skills among response staff. The exercise included the following components:

Observation #1

CER staff evaluated aspects of the following elements: No non-compliances were identified during this exercise. During the exercise, it was noted that the boom deployment vessel towed the secondary boom in a way that caused the secondary boom to cross over the primary containment-boom. This submerged the primary boom which could have resulted in loss of containment of spilled oil in a real incident. Tidal conditions also impacted effective deployment of the secondary boom. CER staff, Transport Canada staff and Trans Mountain staff discussed the value of additional training opportunities for Trans Mountain’s boom-deployment team to ensure that safe, efficient deployment of the secondary boom would be completed without jeopardizing oil containment from the primary boom. Consequently, Trans Mountain committed to consider lessons learned from this exercise in future boom deployment training and processes.
 

Compliance tool used: No compliance tool used

Observation 2 - Indigenous Monitor Observation - General Observations

Date & time of visit: 2022-11-07 13:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Indigenous Monitor Observations
As the Indigenous Monitor mentioned I witnessed exactly what the CER is reporting above. The only thing I will add is that the Trans Mountain boom-deployment team recognized their error and had also recognized a correction to it. Thankfully this was only an Emergency Response Exercise and not the real thing. Having said that Exercises such as this are to make improvements and the Trans Mountain boom-deployment team have recognized the room for improvement.

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