Compliance Verification Activity Report: CV2122-043 - Foothills Pipe Lines Ltd., NOVA Gas Transmission Ltd., TransCanada PipeLines Limited


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-043
Start date: 2021-09-14
End date: 2021-09-14


Regulated company: Foothills Pipe Lines Ltd., NOVA Gas Transmission Ltd., TransCanada PipeLines Limited

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):


Rationale and scope:

Verify response capabilities during their Full Scale exercise in Cochrane, AB on 14 September 2021. The exercise will take place in the Willow Creek area (Rocky Mountain Region). The scope of the exercise includes testing the ability of the company's response program, including plans and personnel, to an emergency event involving its Canada Gas Operations. The company will confirm the location and participants at a later date. The company advised that the exercise may be partially or fully virtual due to COVID-19 restrictions. Refer to the areas of improvement identified in CV1718-405 around ICS.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Operation West Path - Emergency Response Exercise Evaluation

Date & time of visit: 2021-09-14 09:00

Discipline: Emergency Management




Exercise Overview; Planning and Design; and Facilitation and Control
On 14 September 2021, Canada Energy Regulator (CER) staff evaluated and participated in NOVA Gas Transmission Ltd.’s (NGTL or the Company) full scale exercise: “Operation West Path”, in Cochrane, AB. Representatives from the Town of Cochrane, Cochrane Fire Department, Cochrane Agricultural Society, Tsuu’Tina Fire Department, Stoney Fire Department, Stoney Nakoda Nation, Kainaiwa Resources and the RCMP were present as participants and/or observers. CER staff filled the roles of Federal Incident Commander, Public Information Officer and CER Safety Officer as part of exercise play.  

CER staff noted that the Company had not identified the CER as a key participant in its early stages of exercise planning. CER staff are willing to participate in future pre-exercise planning meetings.  
A participant package was distributed in advance of the exercise which included:

The Company’s exercise objectives were: 
  1. Progress response capacity in a COVID-19 environment through standing up initial field response, completing an Incident Command System (ICS) 201, providing remote REOC support and practicing initial stand up of an ICP.
  2. Collaborate with attending local authorities, indigenous communities, landowners, and other stakeholders by practicing notification, liaison, and communication procedures during response.
  3. Offer to form Unified Command (UC) with the local fire department Authority Having Jurisdiction and practice involvement of other participating emergency services as Assisting Agencies.
  4. Focus on meaningful exercise participation over quantity of response procedures – prioritize slowing down exercise plan over forcing a broad scope of functions in a single day. 
The simulated scenario for this exercise involved a low-pressure alarm on the Western Alberta System Mainline Loop Rocky View Section. CER staff noted that the scenario was designed in consideration of the hazards and risks posed to the Company’s operations in the area. Upon arrival on site, the Company on-call technician confirmed loud audible noise and debris coming out of the ground, next to an abandoned post pounder. The exercise consisted of three locations: field, incident command post (ICP) and a regional emergency operations centre (REOC). Observers, players, controllers, and evaluators were split between the three locations for the first half of the day before all convening in the ICP for the afternoon.

The facilitator conducted a safety briefing that included the identification of the potential hazards that participants may be exposed to during the exercise, the controls to mitigate these hazards, required safety equipment, PPE, and COVID-19 precautions. CER staff did not observe the identification of other safety information – such as exits, muster points and washrooms at the REOC or ICP. CER staff are of the view that ensuring this information is provided would further contribute to ensuring the safety of all attendees.
The Company provided an exercise and program overview that included: 
CER staff noted that the lessons learned identified in the list below were derived from previous CER exercise reports or other areas for improvement identified by the Company. These lessons learned included:CER staff noted that the Company considered these previous learnings and put a concentrated effort into addressing them and explored initiatives that had previously not been incorporated into the exercise play. CER staff observed the following:In the ICP, the documentation unit kept records throughout the exercise and went to each section to provide direction on how to manage the documents for retention purposes. CER staff noted that participant feedback forms were given and collected in the REOC.
Injects appeared appropriate, however, CER staff observed that it was unclear how the injects were communicated, tracked, and managed, including task progression, throughout the exercise. It would be beneficial to have a defined process for managing injects that is clearly communicated and understood by all participants and allows for tracking of injects from start to finish.
CER staff noted that NGTL made concentrated efforts to support the continued learning and coaching of responders throughout the exercise. This included the insertion of the Incident Management Assistance Team (IMAT) into exercise roles to support exercise play and utilizing a “TIME OUT TIME IN” system to allow participants to request a coaching moment outside of exercise play.

At the field site, CER staff observed that some observers – who were not required to wear personal protective equipment (PPE), did not initially remain in the stanchioned areas designated for exercise observers. This was corrected by the Company and observers were moved to the prescribed area.

Notification and Reporting
CER staff observed that the roles of the Company versus emergency services did not appear to be clearly understood at the field level. The Company First Responders were unsure of who would be conducting the required municipal and provincial notifications and relied on the Cochrane Fire Chief for advice. CER staff are of the view that a clear understanding of the roles and responsibilities, including notification and reporting requirements would facilitate the timely execution of these functions. 

The Company reported the exercise using the exercise reporting function in the Online Event Reporting System (OERS) early in the exercise. CER staff noted that this is an improvement from previous exercises.

CER staff observed that the product and product characteristics or SDS sheet were not identified or posted in either the ICP or the REOC.  A safety plan was developed and posted on the incident status board. However, it was not clear whether it was widely disseminated or continuously updated throughout the exercise.

CER staff observed that a safety meeting was conducted that reviewed the site-specific hazards and controls for participant safety but that there was no sign off of a Job Hazard Analysis or Field Level Hazard Assessment at the field location. CER staff are of the view that incorporating this practice into the exercise would add realism as it was noted that this would typically occur if it were a regular incident site. CER staff noted that Company First Responders and identified field personnel had appropriate PPE.

Response Management
The Company relied on its emergency procedures manuals (EPM) and supporting documentation and tools to respond. ICS was used, and Company personnel demonstrated knowledge of and training on ICS, including awareness and utilization of the basic principles.

During the exercise, the REOC was stood up prior to the incident being confirmed from the field and immediately began collecting information and deploying resources to stand up a field response and ICP. As a result, the usual steps in NGTL’s emergency response process occurred out of order or simultaneously between the field and REOC. CER staff observed that this led to challenges in synchronizing the work between the REOC and the field. This view was also supported by comments from NGTL staff during the exercise debrief. To avoid this situation, CER staff recommend that NGTL use and document time jumps within the scenario to facilitate the process occurring in the proper sequence and avoid confusion between activities occurring in the field and the REOC. CER staff observed that Company personnel adhered to their roles in the REOC, but the roles were not easily identifiable. It would be beneficial to incorporate visual aids such as: vests, table markings etc. to facilitate identification of the specific sections/roles. 

The Company First Responders relayed field information to the REOC through an open call using the MS Teams platform. CER staff noted that the REOC actively monitored communications from the field and promptly answered requests or check ins that occurred outside established times. Field and REOC personnel established and maintained check in times appropriately. NGTL first responders were observed to be actively referring to their job aids and filling out and updating the ICS 201 Incident Briefing form.

An effective transfer of command from the initial NGTL IC to the incoming IC was conducted in the field using the ICS 201 Incident Briefing form to brief the incoming IC. The incoming IC asked appropriate questions to better understand the situation and developments up to that point in time. UC was formed in the field between the Company and the Cochrane Fire Department. The Cochrane Fire Chief indicated that they would also be serving as the liaison for the Town of Cochrane. The Stoney Nakoda Fire Department and the RCMP were identified as assisting agencies.

A formal meeting schedule was not established, however, call back/next meeting times were discussed.  Meetings were orderly, and the Planning Section Chief (PSC) followed the prescribed agenda outlined in The Response Group (TRG) (an emergency response consultant) job aid. However, CER staff observed multiple different job aids being used, including TRG, United States Coast Guard and NGTL. CER staff are of the view that the use of one job aid would contribute to consistency of messaging and shared understanding of expected roles and responsibilities for Company personnel.   

Response priorities and objectives were identified and appropriate for the scenario, however, CER staff observed confusion over terminology, objectives, and priorities. As a result, response objectives were difficult to establish as Company personnel were unclear of the difference between objectives, strategies, and tactics. The CER Federal Incident Commander (FIC) provided input to help focus the setting of objectives, strategies, and tactics. The Company confirmed the use of PPOST (Priorities, Problems, Objectives, Strategies, Tactics) as the tool used for complexity analysis and to size up the situation and determine initial actions. CER staff are of the view that determining how PPOST aligns with the setting of objectives, strategies, and tactics under ICS would be beneficial to ensuring a shared understanding of terminology and the setting of priorities, objectives, strategies, and tactics.

CER staff are of the view that a process for initial UC interactions in the field and visual role identification would assist in a more fluid integration of additional agencies and facilitate collaborative planning. Vests were used in the ICP to identify critical roles but CER staff observed that it was difficult to identify the roles of field personnel. CER staff noted that when the Cochrane Fire Department arrived on scene, they immediately began planning response activities prior to being acknowledged by Company personnel, and ultimately had to interject and ask who was in charge for the Company.

CER staff observed that apart from maps provided in the participant package and shown during exercise introductions/briefing, maps did not appear to be widely used. One map of the incident area and plume was provided to the REOC before it was stood down. There were no visible maps noted in the ICP. The Incident Status Board contained minimal information and did not appear to be actively updated during the response. CER staff are of the view that an accessible method to capture and display up to date incident information, including maps, would assist in the dissemination of information to all individuals required.
The “planning p” was followed throughout the exercise. CER staff noted improvement in how far into the “planning p” the Company progressed compared to what has been evidenced in the past. Company and CER staff noted that there were a lot of activities to execute in a small amount of time. The Company could consider using time jumps and focusing on specific stages of the “planning p” rather than going through each stage every exercise.

In summary, CER staff observed several challenges created by:CER staff are of the view that these challenges led to a disconnect and lack of alignment and communication/direction between:Response Communications Technology
CER staff observed that communications with other First Responders and agencies were not discussed and that the First Responders and assisting agencies worked independently of Company personnel to establish a common radio channel to use during simultaneous evacuations. CER staff did not observe how, or if, this information was communicated to the Company.

CER staff noted that the primary communication methods for the REOC and Field were cell phones and MS Teams for virtual mobilization. These methods proved effective, and it was noted that the Company was able to invite outside agencies into the REOC using either option.

External Communications
Communications audiences identified included residences/anyone in the affected area, the City of Cochrane and surrounding area, Indigenous Communities in the area and media. CER staff did not observe a documented strategy, but it was clear that the Public Information Officer (PIO) was developing communications materials strategically. The primary strategies and platforms used/planned for external communications were the Alberta Emergency Alert system, the Company Website, Media Advisory, and a Press Conference.
A state of emergency was enacted for the area and an Alberta Emergency Alert was issued to those directly impacted (i.e.: who was to evacuate, who was to shelter in place, and everyone else to stay away from the area). A holding statement was completed and approved, but it wasn’t clear to CER staff how it was issued. NGTL advised that they activated their website for emergencies and that this would have been done in within an hour or two of the incident.
A joint press conference between NGTL and the City of Cochrane was approved to be held at 16:45. The public would be notified via media advisory and NGTL would issue their next update just prior to the press conference. CER staff observed that the this could result in a big information gap given the holding statement was issued at noon and the next update wasn’t going to be issued until just prior to the press conference. Due to time constraints, an official JIC wasn’t stood up, however coordination for how a press conference would work was discussed between NGTL, City of Cochrane and the CER.
Tactical and Strategic Response
CER staff noted that Company First Responders should establish better communication with their field staff to provide up to date safety information so that responding agencies have the information they need to respond safely. For example, CER staff noted that there was limited discussion of the potential plume or air monitoring until the Company Environment Field Personnel demonstrated an app on their phone that provided plume modelling. It indicated that the plume was heading straight for the Town of Cochrane. CER staff also observed that when the Cochrane Fire Chief asked if authorities conducting notifications and evacuations in Cochrane would be going into the plume, the Company First Responders were initially unsure.

In the REOC, the focus was on hazard monitoring, evacuations, notifications, and ordering resources. CER staff observed that there was a lack of alignment and communication at times between activities in the REOC and in the Field during the initial hours of the response. For example: 
Public Protection
CER staff noted that impacts to communities and nearby users were discussed in detail and were the focus for REOC staff; however, in both the field and the REOC, CER staff noted that initially, there was limited discussion around residents being told to shelter in place in areas impacted by the gas plume as evacuation was the primary mitigation for these residents. As the incident progressed, discussion on the use of shelter in place orders and evacuation alert orders became more prevalent.

The Fire Departments and RCMP managed evacuation of residents within the impacted area; however, it was not clear how the evacuation plan was communicated and coordinated between NGTL, the Fire Departments, and the RCMP.  CER staff observed that collaboration between the Company First Responders and Municipal First Responders should have been integrated to facilitate effective evacuation of residents and to ensure the safety of all responders.

Environment Considerations
CER staff did not observe the identification of environmentally sensitive areas for protection in the REOC or discussion of pre-determined mitigation measures and resources to manage wildlife. Various environmental considerations were discussed in the field and ultimately determined to not be an immediate concern due to prioritization of life safety as well as the nature of the incident, a relatively short-term, sweet natural gas rupture.

Post Exercise
Participants and evaluators were grouped to provide feedback during the debriefing. During the debriefing participants and evaluators were asked to provide successes, challenges, and opportunities for improvement. These were documented by the Company and it was indicated they would be considered for future exercises and learning opportunities.

Virtual Environment
To accommodate virtual participation and facilitate communications between the REOC and the field, MS Teams was used. Overall, both CER and Company staff felt this worked well, however minor issues with connectivity occurred at the ICP. This was due to the type of building (metal) and a lack of internet.


Compliance tool used: No compliance tool used

Observation 2 - Information Request (IR) #1 - Documentation Request

Discipline: Emergency Management




NOVA Gas Transmission Ltd. (NGTL) has pipelines and/or facilities regulated by the Canada Energy Regulator (CER) and is therefore subject to the Canadian Energy Regulator Act (CER Act) and its associated regulations. In order to prepare for the upcoming exercise in Cochrane, AB on 14 September 2021 CER staff require that NGTL respond to the information request by 01 September 2021. 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Follow instructions in the Documents section to upload and submit documents, as requested below, by the specified due date.

CER staff request the following documentation:

Due date: 2021-09-01

Date closed: 2021-09-01
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 3 - Information Request # 2 - After Action Report (AAR)

Discipline: Emergency Management




CER staff noted several areas for improvement during the exercise. To ensure that the elements identified in the emergency response exercise evaluation report are considered or addressed and incorporated into NGTLs emergency management program CER staff are requesting an after action report be filed. 


Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

NGTL  is requested to file an after action report. Follow instructions in the Documents section to upload and submit the AAR by 04 February 2022. The AAR should describe:

The AAR should also include improvement planning such as a corrective action plan (CAP), that identifies program improvements and the necessary corrective actions required to address them, and an improvement plan, identifying the corrective actions to be taken, the responsible party or agency, and the expected completion date.

Due date: 2022-02-04

Date closed: 2022-02-04
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

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