Compliance Verification Activity Report: CV2122-088 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-088
Start date: 2021-05-26
End date: 2021-05-27

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 and overall safety during TMPU's spill deployment drill into the North Thompson River during spring freshet. The drill will occur on 26 and 27 May 2021.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - North Thompson District Spill Deployment - Emergency Response Drill Evaluation

Date & time of visit: 2021-05-26 08:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Observations
On 26 -27 May 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 Blackpool, British Columbia. This location provided good accessibility and observation by all observers. An Indigenous Monitor (IM) from the Indigenous Advisory Monitoring Committee for the Trans Mountain Expansion Project and existing pipeline (IAMC-TMX) attended with CER staff. The purpose of this exercise was to validate response procedures and deployment strategies within the North Thompson District Geographical Response Plan. The exercise was broken down into two days. Day 1 consisted of instruction and dryland training in the morning and an instructor-led equipment deployment in the afternoon. Day 2 consisted of a Trans Mountain-led equipment deployment. This exercise was carried out as required under the Onshore Pipeline Regulations.
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 as:

 
Day 1 consisted of instruction and dryland training in the morning and an instructor-led equipment deployment in the afternoon. The morning training was organized into three instructor-led stations, based on the following: boat operations; an oil spill containment and recovery (OSCAR) trailer; and a decontamination trailer. CER staff observed this training to be detailed and hands-on and noted positive engagement of trainees. CER staff observed trainees and instructors discussing differences in procedures that were being instructed during this training compared to procedures taught in previous training. Expectations of the training audience needs to be clear on when different response procedures are intended to be used. The afternoon training was an instructor-supported hands-on deployment of spill containment equipment on the North Thompson River. CER staff observed the river conditions to be a realistic and challenging training environment. Trainees applied the procedures and techniques from the morning’s training. Due to river conditions, these procedures proved unsuccessful. CER staff observed the trainees adapt their response tactics to the condition at hand and eventually achieve successful deployment of containment boom.

Day 2 started with a member of the Simpcw Nation offering a prayer and presenting an opportunity for all participants to offer tobacco to the river as a show of respect and to ask for a safe training day.

Day 2 consisted of a Trans Mountain-led equipment deployment based on the instruction and learnings from Day 1. CER staff observed effective establishment and use of the Incident Command System (ICS) to organize and manage the simulated response operation. This included assigning key ICS roles, establishing an on-scene Incident Command Post, establishing the on-water and on-shore response teams, and identifying the site’s hot, warm and cold zones. CER staff observed the Incident Commander, Operations Section Chief and Safety Officer deliver effective briefings detailing individual boat tasks and objectives, outlining the decontamination plan and location, and explaining the overall containment and recovery strategy. During conduct of the drill, CER staff observed responders apply the lessons from the previous day’s training to the Day 2 site and river conditions. Responders had to adapt their plans and procedures to find a viable deployment and containment solution. CER staff observed that effective containment and recovery operations were established in approximately two and a half hours, well under the company’s target of four hours. CER staff also observed effective use of a decontamination corridor for any workers entering or leaving the hot zone.

Safety
Prior to the commencement of training on Day 1, Trans Mountain required all participants and observers to complete a COVID-19 self-declaration confirming all attendees are healthy. TM exercise facilitators organized all participants into three groups for the dryland training: minimizing required interactions with individuals outside individual groups. Despite participants and observers being separated into smaller groups and the training being outside, TM still enforced social distancing and the wearing of masks. Sanitization tables were also available for the duration of the two days of training and encouraged to be used. When social distancing could not be maintained during specific parts of the training, mitigations followed TM’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 instructors/staff.
CER staff observed the effective use of an overall general safety meeting at the start of the two-day drill and of job hazard assessments and safety briefings at the start of each training day. CER staff also observed effective use of a safety watch during the conduct of the training. Safety buoys were placed upstream and downstream of the exercise location notifying any others river users of the exercise-related activities. Safety risks, particularly with respect to working on and around the river, were identified and appropriate measures were taken, and personal protective equipment (PPE) worn. CER staff observed trainees taking a positive and proactive approach to safety during the conduct of the training.
 
CER staff are of the view that Trans Mountain promoted and took appropriate measures to ensure a safe training environment.
 
Communication
Ship to shore communication, as well as communication between the vessels, was achieved through the use of radios. Extensive communication was needed to coordinate anchor sets, buoy status and movement of response equipment between the vessels and the shore supervisor. CER staff were provided with a radio to monitor the communications and observed it to be effective throughout the drill. CER staff note the importance of ensuring all groups have their radios turned on and that they are set to the correct channel(s) in order for communication to be as effective as possible. 
 
Post Deployment
Overall, all 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 with other local first responder organizations during tactical response operations.

The training demonstrated that the deployment of response strategies associated with control point 38-04 of the North Thompson Geographical Response Plan could be executed in an effective and safe manner.  Trans Mountain responders utilized their emergency response plan 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

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