Compliance Verification Activity Report: CV2122-087 - Trans Mountain Pipeline ULC


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-087
Start date: 2021-10-04
End date: 2021-10-07


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 spill deployment drill on 5 and 6 October 2021 in Kamloops, BC. Exact watercourse to be determined.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Kamloops District Spill Deployment - Emergency Response Drill Evaluation

Date & time of visit: 2021-10-06 08:00

Discipline: Emergency Management




Exercise Overview / Participants
On 5-6 October 2021, Canada Energy Regulator (CER) staff attended Trans Mountain Pipeline ULC’s (Trans Mountain) equipment training and equipment deployment in the North Thompson River in the town of Kamloops, British Columbia.
The location provided good accessibility and vantage points for observers. Two Indigenous Monitors from the Indigenous Advisory and Monitoring Committee (IAMC) for the Trans Mountain Expansion Project and existing pipeline (IAMC-TMX) attended with CER staff.
An exercise plan was provided to all participants and observers in advance of the training and outlined planning responsibilities, the training and exercise plan, and exercise responsibilities. Trans Mountain’s exercise and training objectives were identified within the exercise plan and were documented to demonstrate the implementation of emergency procedures ensuring the safety of personnel by:

The purpose of this exercise was to validate response procedures and deployment strategies within the Trans Mountain’s Kamloops District Geographic Response Plan (GRP), specifically the strategy outlined for Control Point 43-08 utilizing a Trans Mountain Oil Spill Containment and Recovery (OSCAR) and decontamination trailer.

Exercise Planning and Design
CER staff and Trans Mountain facilitators participated in two meetings prior to the exercise to discuss overall planning and design, facilitation and control requirements, Indigenous considerations, and a list of internal and external attendees. Following the pre-exercise meetings, Trans Mountain provided CER staff with the Kamloops District GRP and other emergency response documents including the Emergency Response Plan (ERP). CER staff had sufficient time prior to the exercise to review exercise documents including objectives and provide recommendations and feedback. The attendees list included individuals from Trans Mountain, the British Columbia Ministry of Environment and Climate Change Strategy, Tk’emlups te Secwepemc First Nations, and contractors from First Response and Proactive to assist with the exercise.
Exercise Facilitation and Control
Prior to each day of training, Trans Mountain facilitators and designated Safety Watch completed a review of the deployment plan, site orientation and safety meeting. Due to the high public traffic in the area used where the training was taking place, additional details on ensuring public safety were discussed. Trans Mountain completed all required facilitation and control measures prior to the training as set out by the specific Trans Mountain Safety Standards.

CER staff observed Trans Mountain complete an overall general safety meeting at the start of the training and of job hazard assessments and safety briefings at the start of deployment specific to response tactics and associated hazards.

CER staff also observed use of a Safety Watch during the training. Safety risks, particularly with respect to working on and around the river and pinch points, were identified. Appropriate measures were taken, and personal protective equipment (PPE) worn to mitigate these hazards. Trans Mountain described the safety concerns pre-determined in the Kamloops GRP and followed the ‘Incident Safe Approach’ protocol when initiating the training. Trans Mountain also completed the Initial Site Health & Safety Plan, Tailgate Meeting/Hazard Assessment Form and reviewed these documents with all response personnel.

Product type was identified and the appropriate Safety Data Sheet was posted on the safety trailer where the tactics meetings were held. The specific hazards and first aid treatment were discussed during the safety meeting ensuring all responders were aware of the product hazards.
Control zones were established as per the Tran Mountain Kamloops GRP and ERP. The decontamination area was established quickly and clearly identified the ‘warm’ transition zone between the hot and cold response zones. Trans Mountain responders were observed by CER staff utilizing the decontamination area throughout the duration of the exercise.

Trans Mountain completed the required briefings prior to the training. IM’s however observed several instances of improper and unsafe equipment unloading techniques were observed by shoreline teams while unloading response equipment from trucks. The IM's safety concern is documented within the Indigenous Monitor Observations report. CER staff recommend that even though major site safety concerns were discussed, the safety briefings should also keep identifying the basics of safe techniques for offloading potentially heavy equipment.

Response Management
CER staff observed Trans Mountain utilizing the Incident Command System (ICS) to organize the deployment for the exercise. During the initial response period, prior to deployment, Trans Mountain completed a briefing where the pre-determined Incident Commander designated additional roles, response actions and objectives. The ICS structure is formally integrated into the Trans Mountain ERP and promoted a clear chain of command, communication expectations and resulted in a successful boom deployment.

Trans Mountain utilized the training area as the Incident Command Post (ICP) and displayed drawings of deployment strategies, required equipment, individual team responsibilities and communication requirements. The observed resources displayed in the ICP were consistent with what was outlined in the Trans Mountain ERP.

Response Communications Technology
Ship to shore communication, as well as communication between the boats was achieved using radios. Extensive communication was needed to coordinate anchor sets, buoy status and movement of response equipment between the boats and the shore supervisor. Cell phone and radio communications are outlined in the GRP as the two methods of communication available at this location.
Tactics and Strategic Response
Trans Mountain tested the strategies and tactics outlined in their Kamloops GRP Data Sheet for Control Point 43-08 and ERP. The training included the use of one OSCAR trailer, a decontamination trailer and three boats owned by Trans Mountain. The implementation strategy outlined for Control Point 43-08 includes the installation of a 600-foot-long boom product collection point as well as an 800-foot-long deflection boom. For the training conducted on 6 October 2021, Trans Mountain successfully completed the installation of the collection point which included 800 feet of boom, drum skimmer and recovery operations on shore within the company’s targeted deployment time frames.

Environment Considerations
CER staff and exercise participants were briefed on an environmental assessment completed by a Trans Mountain Environmental Watch as per their Environmental Protection Plan. Further to the completed environmental assessment, Trans Mountain was observed referencing their Kamloops GRP which specifically outlines shoreline information, wildlife at risk and wildlife mitigation tactics for this specific control point location. Wildlife mitigation practices were not part of this exercise.

During the exercise, the dedicated Environmental Watch was responsible for communicating the potential environmental impacts of the exercise and the associated mitigation strategies to prevent any potential environmental damage as a result of the training. CER staff are of the view that this was a good practice and that Trans Mountain’s commitment to minimizing the environmental impact due to the training was effective.

Other Considerations: Pandemic
Prior to the commencement of training, Trans Mountain required all participants and observers to complete a COVID-19 self-declaration as part of their COVID-19 Self Declaration and Guidance policies, confirming all attendees are healthy. Trans Mountain exercise facilitators enforced social distancing and the wearing of masks throughout the duration of the exercise. Sanitization tables were also available during training and good sanitization practices were encouraged. When social distancing could not be maintained during specific parts of the training, mitigations followed Trans Mountain’s “Safety Precautions When Working Within 2m of Other Workers”. CER staff are of the view that these pandemic-related measures were appropriate for ensuring the health and safety of training participants, observers and facilitators.

Post Deployment
Overall, all of the exercise objectives were met. Exercise participants were engaged and actively participated in all aspects of the training. During the exercise debrief, the feedback from participants and observers was positive; the key points were that the training was educational and provided an opportunity to cross-train responders and to work together during tactical response operations.

The training demonstrated that the deployment of response strategies associated with Control Point 43-08 of the Kamloops GRP could be executed in an effective and safe manner.  Trans Mountain responders utilized their ERP and established a response structure to manage the response efforts. The response strategies practiced included establishing a decontamination corridor and the effective employment of oil spill containment and recovery equipment.

Compliance tool used: No compliance tool used

Observation 2 - Indigenous Monitor Observations

Date & time of visit: 2021-10-06 08:00

Discipline: Emergency Management




The following section contains independent observations made by an Indigenous Monitor who accompanied the Canadian Energy Regulator Inspection Team during this exercise, as part of the NEB’s commitment to the TMX/Line 3 IAMC’s Indigenous Monitoring Program. They are reproduced and publicized within my report for greater transparency. They are not my conclusions but represent one source of information among others I have considered throughout the exercise evaluation along with my own direct observations and information received from Trans Mounain.

IM Observation:

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