Compliance Verification Activity Report: CV2021-473 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2021-473
Start date: 2020-09-01
End date: 2020-09-02

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

As part of the continual regulatory oversight of TMPU, CER staff will evaluate TMPU's response capabilities during their emergency response exercise held in September 2020.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Exercise Overview

Date & time of visit: 2020-09-02 08:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

On 1-2 September 2020 Canada Energy Regulator (CER) staff attended Trans Mountain’s (TM) equipment training and exercise-deployment in the North Thompson River at McMahon Riverside Park in Clearwater, BC. This exercise was carried out as required under the Onshore Pipeline Regulations.

An Indigenous Advisory Monitoring Committee (IAMC) Indigenous Monitor (IM) was also in attendance, as well as a Simpcw community member was hired as a ‘salmon watch’ to ensure there were no impacts to fish. No fish were reported during the exercise.

The exercise followed a training day where TM response staff laid out equipment for re-familiarization in the morning and to discuss safety and tactical considerations of the different apparatus, followed by deployment of boom into the river in the afternoon.

The exercise plan for this event is attached, and was received prior to the exercise date.

Trans Mountain chose McMahon Riverside Park as the exercise location due to its proximity to existing control points as found in their Geographic Response Plan (GRP). The location provided good accessibility and visibility for observation. It was noted that due to the river channel being bisected by an island, the flow pattern of the river was a difficult area to deploy in. This created a more challenging exercise for the TM response staff and was noted as being beneficial to expanding their abilities.

The scenario for this event, as outlined in section 3.2 in the exercise plan, is “A pipeline release at KP 680 has resulted in product entering the North Thompson River upstream of Clearwater. CP 38-03 has been selected as the deployment location.” The exercise plan also states the objectives for the exercise in section 3.3:

“Exercise Objectives
1. Ensure required COVID-19 safety protocols are outlined at the beginning of each day and subsequently abided by throughout the exercise.
2. Demonstrate the implementation of emergency procedures ensuring the safety of personnel by:
a. Assigning a Safety Watch and Environmental Monitor.
b. Complete the Initial Site Health and Safety Plan and conduct a safety briefing/tailgate meeting
c. Conducting boat safety briefing for all boat crews by each boat captain.
d. Establishment of a decontamination zone.
3. Demonstrate the safe deployment of response equipment per Control Point 38-03, or an alternative strategy based on river conditions at the time of the exercise”

Both days began with a morning meeting, consisting of an overview of the day’s activities and a tailgate safety meeting. This met the requirements of Exercise Objective 2(b). The training day also began with a welcome and a prayer from the local Simpcw First Nation as the exercise location is within the Nation’s traditional territory.

The training day, 1 September 2020,  served to expose CER staff, IM’s and Trans Mountain staff to response equipment, provide for relationship building and provide greater familiarity with Trans Mountain’s existing control points in the company’s GRP. At the conclusion of the training day, TM staff identified challenges to a response in the area as conditions in the river were impacting the response equipment and causing some bowing of the boom.

On 2 September 2020, the deployment exercise began with a safety meeting and an overview of the objectives of the day’s exercise. The boat teams deployed down to the boat launch - BL 38-02 -as listed in the GRP.

Responding to learnings from the previous day, Trans Mountain staff adjusted their tactics and completed an effective boom set. These adjustments included re-positioning the anchors, adding additional hand lines and altering the angles of those hand lines to ensure a more consistent angle of boom. The first anchor was set at 09:27, with the boom set being completed (Two hundred feet of boom attached to the skimmer and fifty feet of shoreline boom) at 10:14.
 

Compliance tool used: No compliance tool used

Observation 2 - Safety

Date & time of visit: 2020-09-02 09:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Each day a thorough safety briefing was held in a tailgate style meeting. Some of the considerations listed included lifting concerns, working around water, COVID-19 protocols, security concerns and public interactions, identifying first aid attendants, and potential issues due to weather and heat.   

When on-water operations were scheduled to begin, the boat crews would depart McMahon Park to a downstream boat launch. At the boat launch, the boat captains were to hold a second safety briefing specific to the vessel safety, as required by Objective 2(c).

A safety watch was stationed at the exercise site and an additional safety vessel was used to maintain a position downstream from the working vessels in the event of a man overboard situation. An environmental checklist was also filled out by the Environmental Monitor, which met the requirements of exercise objective 2(a).

Trans Mountain staff working from shore were tied off with a harness system and a safety spotter when working with hand lines. All staff working near or on water also wore personal flotation devices. The safety boat was used as a backup in the event shore line staff slipped into the water.

A summary of the safety plan is in section 4.3 of the Exercise Plan. It was noted that the vessel operators showed good control of the jet boats, even with the fast current and flow pattern in the particular stretch of river they worked in.

COVID-19 precautions were in place throughout both days. All attendees wore face masks when social distancing could not be maintained. Hand sanitizers and disinfectant wipes were also available for exercise participants. This met the requirement of Exercise Objective 1.
 

Compliance tool used: No compliance tool used

Observation 3 - Response Tactics

Date & time of visit: 2020-09-02 10:00

Discipline: Emergency Management

Categories:

Facility:

Observations:


Trans Mountain staff followed the protocols listed in the GRP for response to this section of river. On the training day it was identified that the tines of the anchor were configured in a way that made it more difficult for the anchor to set into the cobble. This was taken as a learning, and the following day the location of the anchor’s position was altered slightly, which resulted in a faster and more secure anchor set. The training day also discussed proper ratios for length of anchor lines and ballast chains compared to the depth of the water. Trans Mountain staff also applied this the following day to improve the final boom set.

Two hundred feet of boom was deployed to deflect product from the main current of the river to the shore. The deflection boom was attached to a weir skimmer and 50 feet of shoreline boom was also used. Despite a steep drop of approximately 15 feet, Trans Mountain staff were able to pump water up from the river into temporary containment. Trans Mountain further amended the original response plan by adding additional hand lines to help straighten the boom from what they achieved in the training day. A decontamination station was also successfully set up as per Exercise Objective 2 (d).

The resources that Trans Mountain deployed to this exercise included approximately 28 staff (including CER and IMs), an OSCAR (Oil Spill Cleanup and Response) trailer, a boom trailer, 3 jet boats and a decontamination trailer. Spill response contractors were also used to assist during the training day. They displayed a high degree of technical knowledge and ability, and were able to communicate technical information efficiently and effectively.

Trans Mountain’s staff showed a high degree of ability to adapt plans quickly and use alternate tactics to achieve a successful response. An example of adaptability was how Trans Mountain staff addressed water conditions and efficiently adjusted the boom strategies and tactics in the response. Trans Mountain staff were able to adapt boom strategies and tactics to address water conditions in order to complete the boom set up efficiently. By the end of the exercise Trans Mountain staff had met all the exercise objectives.

Compliance tool used: No compliance tool used

Observation 4 - Communications

Date & time of visit: 2020-09-02 09:00

Discipline: Emergency Management

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Facility:

Observations:


Ship to shore communication, as well as communication between the vessels, was achieved through radios. The communication was observed to be effective as extensive communication was needed to coordinate anchor sets and movement of response equipment between the vessels and the shore supervisor. CER staff also noted that cellular reception was strong in that area, which confirms the information listed in the GRP.

Compliance tool used: No compliance tool used

Observation 5 - Indigenous Monitor Observation

Date & time of visit: 2020-09-02 09:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Day - 1
Day started with an introduction from trans mountain emergency response team, two CER officers, IAMC monitor Simpcw First Nation, fisheries manager Simpcw First Nation, and a environmental monitor for SRG also Simpcw First Nation. And one environment specialist from the Kamloops First Nation.

A safety meeting took place after words with most all of us dawning masks and Ones without were distanced no concerns. Safety meeting kicked off with trans mountain rep discussing the days emergency plan pointing out the muster points, washrooms, site description, tripping hazards, weather conditions, and dehydration.

Before the exercise, a brief prayer from fisheries manager and discussion on the salmon spawning and her role as a manager. Trans mountain rep took over from there and discussed the exercise. A site exercise plan was placed on stand for all to see and get to know, and the site and location.

Once everybody was brought up to speed from trans mountain rep on the exercise. A mock run of an actual spill was carried out on land, with rep showing the various equipment to be deployed if an actual spill occurred in a assembly line fashion. After a demonstration of stet up and talk on the various equipment. We had lunch and trans mountain loaded bouts with equipment to be deployed on to boats and then drove to ferry road to unload boats then drive them back upriver to site of exercise.

This was the start of mock spill , first off up stream above sand/cobble island where it splits in two directions a anchor and buoy was placed in left channel facing down river, The left channel will be the site of mock spill . Halfway down left channel a corner is present with island side being shallow, two rake anchors were placed strategically to the current with 100 m rope attached and like the assembly line on shore earlier in training. A buoy was attached then on the left bank a skimmer was placed with hose connected to pump on bank to catch oil and bring to oil contamination bin ( no real oil will be used for the mock) once this was hooked up booms were hooked to buoys and lined up in the current as to catch the spill as it was coming down river the booms were joined to the skimmer down stream on both sides as to not let oil escape . Pump was turned on and water not oil was pumping up to oil contamination holding tank. This oil is later hauled away.

The whole mock took the day, but training interfered with the actual deployment. All in all, no concerns other then plants and grasses are being stepped on and may have to be reseeded and that any salmon that is here be Monitored for spawning. And that spawning habitat is not disturbed.

Also, with the wake that the boats do not churn up the sand below and Colorado the water as this not good on fish guiles. It was a very awesome day safety was good, with no real concerns.

Day two CVA # 2021 -473 emergency response deployment exercise.
No prayer this morning as fisheries manager was not present today.

Safety meeting from trans mountain rep, Then the actual mock started

No real oil used, after a brief discussion on the day’s deployment setup.

A wind device was set up to tell direction. All the cold and hot zones were set up and then the boats were off to unload and later meet up at park for the mock exercise.

Everything was done to the tee from yesterday’s training only with speed and patience. No big concerns on the deployment from start to finish,
One small concern was water was a bit higher and water dark cannot see if salmon present. Dirt was being churned from boats wake could pose a problem to fish but not a problem as the boats only in water a short time. All went well no mistakes were made on the water no concerns. On land only concerns were the vegetation being trampled on, but this is a park, and is also used by the public so the ware was not all done by today and yesterday’s exercises.

Also, upon arrival first day, there was litter on ground and was not done by deployment exercise group. No garbage can was present. One was supplied by trans mountain rep so there were no concerns on our part as cans were being used. Also, many cigarette but’s were all over ground trans mountain had smoking location so no concerns there.

All in all, I feel this emergency deployment was done professionally and all steps were taken to minimizing the footprint here. Exercise went down in an hour and a half if it was a real situation, I’m sure they would have got spill under control.

No concerns from me. It was an awesome learning experience and I wish to have more of these soon. It is good to know trans mountain has plans in place in case of a major spill.
 
 

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