Compliance Verification Activity Report: CV2223-188 - Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2223-188
Start date: 2022-08-04
End date: 2022-08-05


Regulated company: Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership

Operating company: Pembina North Limited Partnership

Province(s) / Territory(s):


Rationale and scope:

Ensure the company is prepared to respond to an emergency. Verify that response actions are based on the EPM and company procedures; assess whether the EPM and procedures protect the health and safety of the public and responders, property and the environment; determine whether exercise objectives were met; and ensure that no effects or potential effects result from participants’ actions or lack of actions. Full scale exercise on 4-5 October 2022 in Manitoba which will include external parties. Drill in Fort St. John 3 August 2022.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Fort St John Spill Deployment - Emergency Response Drill Evaluation

Date & time of visit: 2022-08-04 08:15

Discipline: Emergency Management




Exercise Overview / Participants
On August 4th, 2022, Canada Energy Regulator (CER) staff attended Pembina Pipeline Corporation's (Pembina) equipment deployment in the Peace River in the town of Taylor, British Columbia. 
The location provided good accessibility, room for staging equipment, privacy, and observation points for oversight.

An exercise plan was provided to all participants and observers in advance of the drill date and outlined the responsibilities, objectives and scope. Safety was prioritized and ensured for the drill by having all attendees participate in conducting an initial health and safety plan, listening to a boat safety briefing given by each boat captain, discussing current site safety considerations, assigning a safety watch and medic for the drill, and establishing a proper decontamination procedure and corridor to ensure safety for the surrounding environment.

A refresher training day was hosted August 3rd, the day prior to the drill, to practice and review spill equipment and tactics with assistance from the contracted training providers.

The purpose of this exercise drill was to simulate an emergency spill response scenario and allow participants to assume response roles and undertake response tasks. The exercise also allowed Pembina staff to practice safe boat handling tactics, deploy spill response equipment, review initial spill response actions, and review wildlife and decontamination equipment. 

Exercise Planning and Design

CER staff and Pembina facilitators participated in a meeting prior to the exercise to discuss the exercise planning, design and intent at a high level.

After the pre-exercise meeting, Pembina provided CER staff with an exercise package with detailed exercise scope, objectives, plans, locations, and timelines. CER staff had sufficient time prior to the exercise to review exercise documents. No concerns or issues regarding the exercise package were expressed by CER staff. Attendees for this exercise included CER staff, SWAT consulting staff, and Pembina area staff.

Exercise Facilitation and Control
Prior to the exercise, SWAT and Pembina facilitators completed a site safety plan, orientation and safety meeting with all participants. The area used for the exercise was quiet and private, so no public safety concerns were expected, but situations were discussed for due diligence purposes.


CER staff observed Pembina complete a safety meeting and field level hazard assessment prior to the start of the exercise and prior to deployment of any equipment. The medic on site also delivered a safety briefing and review of medical emergency procedures.

Appropriate personal protective equipment (PPE) was worn by all participants and observers for the duration of the exercise and included PFDs to mitigate any identified hazards.

All exercise participants also had to review and sign a site safety plan and field level hazard assessment form.  The site safety officer reviewed the safety plan and hazards with the entire group prior to training.

The product type that was theoretically involved in the exercise was discussed and the Safety Data Sheet (SDS) was provided by the safety officer. The specific hazards and first aid treatment were discussed during the safety meeting ensuring all responders were aware of the product hazards.

The decontamination unit and associated equipment was deployed and a corridor established with control zones as per the Pembina ERP. This was for display and awareness purposes only on this exercise.

Response Management
CER staff observe a well-organized response by field personnel. The Incident Command System (ICS) was used to organize the deployment. The chain of command was identified and clear between all participants both on shore and on boats. A large display board was used to formally identify deployment strategies, required equipment, personnel and team responsibilities, as well as communication requirements. The boats, anchors, and boom were all deployed successfully in an organized manner.

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 ERP as the two methods of communication available at this location.

Tactics and Strategic Response

Pembina practiced the tactics outlined in their response plans and as per their facilitator’s strategies (SWAT consulting). They deployed their response trailers, 3 boats, wildlife trailer and decontamination unit for refresher training and to review inventory.
The chosen tactic used for the exercise scenario involved deploying anchors, warning signs, 300 ft of deflection boom and 50 foot of shoreline protection boom. The booms were then placed in such as way as to collect product. No skimmers were deployed but were discussed. The deployment was completed within 2 hours, which is within Pembina’s target timeline for initial response.

Environment Considerations

While the scope for this exercise was limited, basic environmental considerations were discussed by exercise participants and included discussion and plans for refuelling safely, decontamination of all equipment and personnel, and cleaning up the exercise site post exercise. The wildlife deterrents were also deployed for demonstration purposes only, and it was emphasized that only trained wildlife rescue personnel would deploy more advanced equipment and handle any impacted animals. Any animals observed during the exercise were not to be disturbed and avoided.

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 review for responders and to work together during tactical response operations.

The training demonstrated that Pembina could successfully and safely deploy their response equipment and select appropriate strategies for the given control point. 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