Compliance Verification Activity Report: CV1920-397 - Centra Transmission Holdings Inc.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV1920-397
Start date: 2019-10-01
End date: 2019-10-01


Regulated company: Centra Transmission Holdings Inc.

Operating company: Centra Transmission Holdings Inc. (Centra, Centra Pipelines)

Province(s) / Territory(s):


Rationale and scope:

As part of the NEB's annual compliance planning, Centra was identified for an exercise evaluation to verify the company's response capabilities.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Centra Transmission Holdings Inc., Tabletop Exercise

Date & time of visit: 2019-10-01 09:00

Discipline: Emergency Management




Exercise Planning and Conduct
The Centra exercise coordinator provided an exercise package containing schedules, maps, objectives and a list of participating agencies. As this exercise was held in preparation of a full-scale exercise (FSE) the intent was to familiarize those agencies in the management of an exercise using the same scenario and objectives for both the tabletop (TTX) and the FSE.

Exercise Objectives & Scenario
The objectives were relevant and common to most of the participating agencies but also included some that were specific to certain agencies.

  1. Test internal and external communications in consideration of the remote area of incident.
    • Identify gaps in communications capabilities (technology gaps)
    • Evaluate notification/response times:
  2. Time for Gas Control to receive the call.
  3. Time for Gas Control to notify Centra.
  4. Time to dispatch personnel to the scene.
  5. Time for personnel to arrive at the scene.
  6. Test implementation of the Incident Management System and Communications Protocol sections of the Emergency Management Program.
    • See attached Emergency Response flow chart.
    • Time to simulate isolation of damaged section.
    • Regulatory notifications.
TC Energy
  1. Test communications between TC Energy and Centra Pipeline Gas Control.
RM of Reynolds Emergency Management
  1. Test implementation of Emergency Operations Center.
  2. Test evacuation procedures.
RM of Reynolds Fire Department
  1. Test response of fire department personnel to a natural gas incident while ensuring their safety and public safety.
  1. Test internal and external communications.
  2. Test response of RCMP personnel to a natural gas incident to ensure their safety and public safety.
RM of Ste. Anne EMS & MB Sustainable Development
  1. Objectives to be determined
The scenario involved a line hit by an excavator while digging a hole in preparation for a directional bore underneath pond/wet area just east of the Centra Spruce Siding Meter Station. The pipeline is damaged by the excavator and gas immediately begins leaking but does not ignite.  The excavator operator immediately turns off the excavator and contractor personnel safely evacuate the site and call 911.

Notification and Reporting
The participants discussed the level of the emergency and how the local, provincial and federal agencies and regulators would be notified, and what information would need to be shared. Familiarity with the Online Event Reporting System (OERS) was demonstrated and the reporting guidelines were discussed.

A Safety Plan for the FSE was discussed, while the tabletop itself presented few risks. Participants identified potential hazards and necessary personal protective equipment (PPE) in the event of a gas release.  The discussion confirmed that local Volunteer Fire Department (VFD) members as well as the Royal Canadian Mounted Police (RCMP) are not equipped with personal four (4) gas monitors TC Energy operators and personnel are equipped with (4) gas monitors as are Centra field operators and personnel. Manitoba Sustainable Development representatives at the exercise advised that they would be able to provide highway reader boards for direction of traffic at the FSE and in a real event should they be required.

Response Management
Centra uses an Incident Command System (ICS) based incident management system. While the response would be nominally ICS-based, apart from the role of Incident Commander (IC), discussion focused on tasks rather than roles. While the incident site is adjacent to a major highway, and close to an important pipeline facility and right of way, the area is isolated. The community is sparsely populated and rural in character. The company Incident Commander would manage the company response remotely; the nearest Centra company personnel would respond from Winnipeg, approximately 1 1/2 hours away or more. The local response would be coordinated by the Fire Chief.
Exercise discussion was centered on large-scale maps that the company provided and which were spread out over the meeting room table. The company confirmed that the primary response objective was maintaining the safety of responders and the public. Participants recognized that the first-on-scene would likely be operators from the TC Energy facility, followed by firefighters and the RCMP.

A general external communication plan was described and would be initiated by the company IC and simulated at the FSE to include notifications. Local coordination with agencies would be managed by the VFD Chief.

Tactical Response
Tactical response was focused on isolating the pipeline, establishing a perimeter around the release site, and diverting highway traffic via safe alternative routes.  The Rural Municipality (RM) of Reynolds initiated the coordination and preparation of a reception centre at the nearby community hall to support displaced local landowners, stranded motorists and transport drivers.  It was noted by participants that the detour routes available may have limited suitability for transport trucks and may be risky in winter conditions or during the rainy season.

A potential incident site for the scenario was identified at the highway turnout known as 'Giant Stump'. The group didn't consider the space in detail but local knowledge confidently predicted that it would be adequate as an on-scene command post to support the Incident Command Post (ICP) at the Fire Hall.
The RCMP detachments (2) represented, focused on traffic management, roadblocks, diversions and detours. They felt that the highway reader boards offered by the representatives at Manitoba Sustainable Development could be useful for public information at the FSE and in an actual event as well.

Vapor monitoring would need to be supplied by contractors from Winnipeg. While the TC Energy site has a windsock, it may not be visible from the chosen command post. The Centra pipeline carries sweet natural gas that is odorized at the compression site downstream of the 'incident' site. The product in the TC Energy pipelines is not odorized.

Post Exercise
The company facilitator asked participants to provide general comments and to evaluate the exercise with respect to preparedness for the FSE. Comments were positive on the value of the exercise in itself and as preparation for the 24 October 2020 FSE.

CER Staff are of the view that the company outreach had been effective in driving preparatory meetings and the exercise itself validated group commitment to the success of the upcoming event.

The comments were recorded by the company and the exercise coordinator committed to providing minutes of the day. EFG-Centra Pipelines submitted the requested comments relating to the tabletop exercise on October 15, 2019.


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