Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Foothills Pipe Lines Ltd., NOVA Gas Transmission Ltd., TransCanada PipeLines Limited
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(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:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Operation West Path - Emergency Response Exercise Evaluation
Date & time of visit: 2021-09-14 09:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
Exercise Overview; Planning and Design; and Facilitation and ControlOn 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:
Compliance tool used: No compliance tool used
Observation 2 - Information Request (IR) #1 - Documentation Request
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)
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.
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:
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.
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