Compliance Verification Activity Report: CV2021-491 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV2021-491
Start date: 2020-06-14
End date: 2020-06-19


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Rationale and scope:

This activity outlines the Emergency Management actions taken with respect to the Trans Mountain incident at the Sumas Pump Station in Abbotsford, British Columbia, on 12 June 2020. As remediation is ongoing, this report only covers the Emergency Phase of the incident, which occurred from 12 June 2020 until 17 June 2020.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Sumas Station Release

Date & time of visit: 2020-06-22 09:00

Discipline: Emergency Management




Incident Summary

The Trans Mountain Sumas station confirmed a release of crude oil on Saturday 13 June 2020. A spill volume estimate was not initially available but the size of the spill was later estimated to be between 150-190 cubic meters (m3). The product released, a light sweet crude, was on the ground of the pump station and entered a storm drain, causing product to migrate to an adjacent field on Trans Mountain property. No waterways were directly impacted by this event at the time of writing this report.

Company Response - Immediate Actions

When the on-site alarms were triggered by the release, Trans Mountain’s internal Security and Data Acquisition (SCADA) system alerted Trans Mountain personnel to a potential issue. The station automatically shut down when sensors recorded sufficient levels of vapours from the spilled product to initiate shut down.

Trans Mountain deployed response personnel to the incident site, who then confirmed the release. The initial responder noted the vapour’s Lower Explosive Limit (LEL) concerns and Hydrogen Sulfide (H2S) levels at the site, and retreated from the incident site on foot to take further response actions. Upon confirmation of the incident, Trans Mountain made the required notifications to regulators and potentially impacted communities and began deploying response resources to the incident site. 

The LEL levels triggered a public safety alert “shelter in place notification” to one local resident who was closest to the site. The shelter in place notice lasted until vapor levels returned to a safe concentration several hours later.

Trans Mountain initially set up an Incident Command Post (ICP) at the Westridge Terminal on Shellmont Street in Burnaby. ICP staff established an Incident Command Structure with the necessary initial command and general staff positions. As per the Emergency Response Plan, Trans Mountain assigned company staff to the following positions: Incident Command (IC), Planning Section Chief (PSC), Operations Section Chief (OSC), Logistics (Log), Finance (Fin), Safety Offficer (SO) Information Officer (IO) and Liasion Officer (LNO).

Early efforts and priorities in the field focussed on public safety and determining the extent of the release. Public safety measures included air monitoring and a shelter in place notice.  Field responders established a field command post with Operations staff reporting back to the ICP, primarily via phone. The initial response actions were conducted per Trans Mountain’s Emergency Response Plan (ERP).  Trans Mountain’s ERP and Sumas District Geographic Response Plan (GRP) are posted on Trans Mountain’s website as per the CER’s Order AO-001-MO-006-2016 - Compelling Publication of Emergency Procedures Manuals online.

Air monitoring continued through the night with personal monitors. LEL and Volatile Organic Compounds (VOC) levels started to stabilize in the early hours of the morning and field staff were able to determine the extent of the spill by walking the perimeter fence. Vac trucks and Hydro-vac trucks were used to remove standing oil and impacted soil. Mobile community air monitoring was established in areas downwind from the incident.
Canada Energy Regulator (CER) Notification and Field Deployment

Trans Mountain discovered the incident at approximately 00:16PDT on 13 June 2020.  As per the CER’s event reporting guidelines, Trans Mountain notified the Transportation Safety Board (TSB) at approximately 01:57 PDT and the TSB subsequently notified the CER. Receipt of this notification triggered the CER’s internal incident triage process and the decision was made to deploy a CER Emergency Management Officer to site.

A CER Emergency Management Officer prepared for mobilization at 08:30PDT on Saturday and then deployed to incident site at 10:30PDT. CER staff followed the CER Field Deployment Operational Guide, which included a health self-assessment and criteria for self-quarantine if symptoms of COVID-19 presented either during or after the deployment. Staff deployed with standard Personal Protective Equipment (PPE) (fire retardant coveralls, steel toe boots, hard hat, gloves, eye protection, and hearing protection) as well as communicable disease prevention kits (hand sanitizer, N-95 face masks, Lysol wipes). The CER Emergency Management Officer arrived at the company Incident Command Post (ICP) in Burnaby at approximately 14:30PDT.

A CER Inspection Officer was deployed from Calgary to conduct an environmental field inspection with Indigenous Advisory Monitoring Committee (IAMC) Indigenous Monitors (IM).  This inspection was completed on 16 June 2020. The findings of that inspection, including the IM’s observations, are separate from this report and can be viewed on the CER’s website - CV2021-454. As of the date of this report, remediation efforts are still ongoing to remove the remaining impacted soil and ensure product has not migrated off site or impacted ground water. The incident is being overseen by the CER’s Environmental Protection team.

Incident Chronology

13 June 2020: The CER Emergency Management Officer arrived at the Burnaby ICP at 14:30PDT. Staff signed in to the ICP and filled out COVID-19 declarations stating they were asymptomatic. COVID-19 precautions were in place at the ICP including personal distancing, access to hand sanitizer and masks. These COVID-19 precautions were followed every day in the field and at the ICP. The CER Emergency Management Officer was given a briefing on the current situation. The pipeline was shut down, no longer releasing product, air monitoring was ongoing and product was being removed from the site. The incident was classified as a Level 2, as per Trans Mountain’s Emergency Response Plan. A hot zone was established, marking the point of impact and area immediately adjacent to it. Next to the hot zone was the ‘warm zone’ where responders enter and exited the hot zone, and where decontamination was established. Outside the warm zone was considered the cold zone; the area of the site which was free from contamination and used as a planning and staging area.
The CER Emergency Management Officer and the Trans Mountain Incident Commander established Unified Command and held an Objectives meeting, followed by the Command and General Staff meeting. The Unified Command created the following objectives for the Operational Period (OP):

The initial operational period was set on a 24 hour basis, running from 07:00-07:00 each day. Two (2) shifts were established to allow for field personnel to work throughout the night during the emergency phase.
Divisions had been established for the field site, with divisions A, B and C identified as work areas. Volume estimates were being calculated but were not yet detailed enough to be accurate. Air monitoring, groundwater monitoring and Wildlife Management Plans were all being developed during this time. The CER Emergency Management Officer learned that the portion of the pipeline that failed had been removed from site and sent for testing at an independent laboratory.
Trans Mountain uses the Incident Command System and all forms and documents generated were saved by the Documentation Unit.
The decision was made to move the ICP from Burnaby to Abbotsford, closer to the incident site.  The CER Emergency Management Officer traveled to Abbotsford in order to be present at the new ICP the following morning.
14 June 2020: At the Abbotsford ICP, the CER Emergency Management Officer was signed in by security staff and completed a COVID-19 declaration. Sumas First Nation representatives and an Indigenous Advisory Monitoring Committee (IAMC) representative came to the ICP.
The Command and General Staff meeting was held with staff in the ICP, communicating with field staff via the Microsoft Teams application. Teams provided communication and file-sharing during the meetings and briefings, and allowed for greater social distancing and less crowding in the ICP.
The incident was stabilizing, the site was secure as spilled product had stopped releasing, there were no impacts to waterways, no report of wildlife impacts, and no product had migrated off company property. The operational period was extended from 24 to 48 hours, due to the stabilization of the incident and the standard recovery efforts being employed. It was agreed that if significant changes occurred, the operational period could be shortened again to accommodate fluctuations in response needs.
At approximately 10:00PDT, an IAMC member, a contractor hired by the IAMC, and a representative of the Sumas First Nation requested access to the physical point of release at the field location, in the hot zone within the area impacted by the released product. This was not possible due to the fact that the individuals lacked the necessary safety training, the proper PPE, or both, which were required to enter the hot zone. Trans Mountain agreed to arrange for training and PPE in order to accommodate site visits.  
Exposed standing oil had been recovered and the majority of product being removed was now oiled debris - mainly impacted soil. Based on calculated flow rates and potential losses of product, Trans Mountain estimated the size of the release to be 150-190 m3.

Sumas First Nation had concerns with potential historical / cultural significance of the area. During a site visit, Sumas monitors located an artifact, which triggered Trans Mountain’s historical and cultural resources mitigation measures. This area was fenced off for protection and was labeled as Division D. 

The pipeline was re-started under gravity-feed only on 14 June 2020. This allowed for product to still be moved across the Canada-U.S. border. At this time, the pumps at the station were not put into operation. This consideration was an intentional public safety measure to avoid powering the pumps which could potentially create an ignition hazard due to any lingering vapours.

15 June 2020: The Trans Mountain Incident Commander and the Planning Section Chief were replaced by other individuals as part of normal staff rotation. Trans Mountain’s policy is to rotate initial response personnel after 4 days to avoid personnel fatigue.

The CER Emergency Management Officer conducted a thorough site tour in the evening. Most of the impacted soil was removed in the hot zone.

The pumps at the Sumas station were restarted on 15 June 2020, as air monitoring had been stable throughout the night showing zero LELs, VOCs and H2S readings. Air monitoring and water quality monitoring were ongoing. The CER Emergency Management Officer consulted with the CER’s Pipeline Integrity team in Calgary to ensure there were no further requirements from Trans Mountain before the restart occurred. The pipeline was started with the impacted section isolated and not in operation. It was confirmed with Trans Mountain that similar fittings used in other locations along the Trans Mountain system had also been visually inspected to ensure they were not at risk of a similar failure.
The removal of product in Division A (the hot zone) was winding down and work was beginning in Division B (the field adjacent to the pump station). The Planning and Operations Sections worked to construct a road into the field site via rig mats to access the site with minimal impact.

An Emergency Response Officer (ERO) from the BC Ministry of Environment and Climate Change Strategy (BCMOE) joined the ICP, working with the Environment Unit (EU). Environment and Climate Change Canada (ECCC) also contacted the CER and notified they would be remotely joining the EU.

An additional CER Inspection Officer arrived in Abbotsford, in preparation of an inspection the following day with two IAMC Indigenous Monitors (IMs). This CER Inspection Officer worked in the Environment Unit, providing clarity on remediation requirements to partner agencies.

16 June 2020: Removal of impacted soils was ongoing. Ground water sampling testing results were received, which showed no elevated levels of hydrocarbon contamination over historical sampling results. The emergency phase, or response phase, of an incident is the focus on the initial actions needing to be taken in order to ensure public and responder safety. It involves dealing with objectives such as incident stabilization and being able to react to unpredictable situations responders face early in an incident. As this incident was showing further stabilization of events, it was determined this would be the last day Trans Mountain remained in the emergency phase. The following day was identified as a shift towards a longer term project/restoration phase which they referred to as the remediation phase. This remediation phase is when a company transitions from being highly reactive, as in the emergency phase, to taking a longer term focus on planning for ongoing remediation and restoration of all impacted sites. Trans Mountain said that it would bore additional sampling wells on its property to assist in determining potential areas of impact.

The CER Inspection Officer and IAMC IMs conducting the environmental field inspection completed their inspection of the field location.

17 June 2020: The CER Emergency Management Officer staff signed off on the Transition Plan to move this incident from the emergency phase into the longer term project / restoration phase. Trans Mountain closed down the ICP and CER Inspection Officer completed their work and turned the incident over to the CER Environmental Analyst based out of the CER’s Vancouver office to oversee the ongoing remediation.
Participating Entities
Responsible Party Regulatory Oversight & Jurisdictional AuthoritiesSummary of Indigenous Peoples Involvement Indigenous Advisory Monitoring Committee (IAMC) / Indigenous Monitor (IM) Involvement

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