Compliance verification activity type: Emergency Response Exercise
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Trans Mountain Pipeline ULC
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Trans Mountain conducted a full scale winter River Deployment Exercise in the Jasper area on January 31, 2018. The exercise included equipment deployment and demonstrated the company’s ability to respond in winter conditions, as well as its proficiency with capturing oil from a waterbody in full ice conditions. Participants included Trans Mountain (TM), First Response Contractors, Western Canada Spill Services (WCSS), National Energy Board (NEB), Indigenous Advisory Monitoring Committee (IAMC) monitors, Simpcw FN, Alexis FN, Parks Canada, Municipality of Jasper, British Columbia Ministry of Environment (BCMOE), Alberta Energy Regulator (AER) Alberta Health Authority (AHA). This exercise also provided NEB staff the opportunity to observe and evaluate winter response tactics and considerations applied in a real world mock situation within the Incident Command System (ICS).
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Exercise Planning
Date & time of visit: 2018-01-31 08:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
Prior to the River Deployment Exercise, an NEB EM Specialist participated in two telephone planning conferences with Trans Mountain staff, providing input on the structure of the exercise. Draft versions of the Player’s Manual were sent out January 15th and hard copies of the final Exercise Plan were available to attendees in the ICP. Personnel were required to sign in and out of the ICP and wear identification badges while on site.Monitors working on behalf of the Trans Mountain Expansion Project Indigenous Advisory Monitoring Committee (IAMC) attended the Trans Mountain exercise with the NEB. A representative of the IAMC monitoring sub-committee also participated in an introductory call with the NEB prior to the exercise. The IAMC monitors recorded their observations and recommendations in an independent report for the IAMC. On 30 January 2018, field personnel completed a full day of dry land training which included demonstrations and familiarization with spill response equipment. Some participants in the ICP observed the dry land training in the morning and attended a spill response equipment tour and exercise overview in the afternoon. Section Chiefs also engaged in an ICS review with their staff. On 31 January 2018, the field deployment was exercised at the Old Fort Point Boat Launch in Jasper National Park. The participants in the ICP conducted a tabletop exercise from development of an ICS 201 Briefing to a Tactics Meeting. The scenario for the exercise involved a third party line strike at KP 379.61 of the Trans Mountain Pipeline at the crossing of the Miette River. The strike resulted in a diesel spill, of approximately 500m3, to the Miette River.The exercise day started at 0800 with a round table introduction of all participants attending or observing, and their respective roles in the exercise. The majority of field staff were not present and were traveling to the field site. Objectives, rules of play and scope of the exercise were reviewed, and participants were provided copies of the Player’s Manual. A safety briefing was also completed by the Safety Officer at the Incident Command Post (ICP). Topics of discussion included muster points, hospital locations in Jasper, potential on site hazards, and stopping the exercise in the event of an actual incident. Objectives set for this exercise were:
Compliance tool used: No compliance tool used
Observation 2 - Notification and Reporting
Due to the volume of the spill, the sensitivity of the receiving environment, and the potential for drinking water impacts, Trans Mountain staff classified this incident as a Level 3, as per the company’s Emergency Response Plan [Trans Mountain Pipeline] (ERP) matrix (See Emergency Levels section in the ‘Introduction’ portion of the ERP for the company’s classification matrix).All external notifications were simulated and no calls were made to external agencies during this exercise. Notification processes were not in the scope of this exercise. The notification list was reviewed to ensure proper agencies were considered.
Observation 3 - Safety
A NEB Safety Officer (SO) worked with the Trans Mountain SO within the ICP to develop the ICP’s Site Health and Safety Plan. An additional NEB SO was not available for the field component of the exercise.A Site Health and Safety Plan (SHSP) and a Medical Plan were developed in the ICP. The SHSP was developed in alignment with Exercise Objectives and Operational Planning, and included an Ice Safety Plan as well as a Hazard Mitigation Analysis. The Ice Safety Plan addressed testing river ice at Control Point recovery locations for suitable load bearing capacity in order to determine whether field staff and equipment could be safely deployed to work on the ice. The Hazard Mitigation Analysis addressed safety measure for working on ice in order to recover spilled product. The Safety Officer and Deputy Safety Officer developed the Hazard Risk Analysis Worksheet (ICS 215a), which identified potential hazards and recommended safety mitigation measures associated with the proposed activities detailed in the Operational Planning Worksheet (ICS 215). The Safety Officer presented the Hazard Risk Analysis to the Tactics Meeting Team and identified potential safety issues and recommended mitigation measures.The Safety Officer responded to two safety related "sim cell injects" for the purposes of this exercise. The first inject was a serious injury to a contract worker (fractured tibia) and the second inject was an employee’s truck colliding with a sheep. Details of the safety incident were reported via email to the KMC Regulatory Group with instructions to determine whether incidents were reportable and to ensure that the appropriate regulatory agencies received a timely initial Incident Notification. Considerations such as mock Lower Explosive Limit (LEL) readings, air monitoring, decontamination as well as use of safety harnesses, retraction lines and safe ice working conditions were all reported to the ICP. Both a Medical Plan and Safety Plan were reviewed and signed off by Unified Command (UC).
Observation 4 - Response Management
Trans Mountain set up an ICP and staffed all necessary roles for this exercise including command staff for Planning, Operations, Finance and Logistics. Span of control did not exceed 5-7 people among the sections. Trans Mountain staff playing new roles were shadowed by more experienced players as part of building additional internal capability and knowledge in Trans Mountain’s response capacity.The NEB had members fulfilling roles in the Environmental Unit (EU), Safety Officer (SO) in the ICP, federal Incident Commander within Unified Command and a federal Deputy Incident Commander within Unified Command. The NEB EU personnel worked with the IAMC's EU representative, and an additional NEB Environment staff member worked in the field with the IAMC's safety specialist. IAMC observers were also located in the ICP and participated in ICS meetings. A Waste management Plan, Wildlife Plan, Air Monitoring Plan, Medical plan, Traffic and Security Plan, Safety Plan, Convergent Volunteer Plan and Communications plan were reviewed and signed off by UC. An operational period of 24 hours was established by UC from 07:00 - 07:00.Unified command was made up of Trans Mountain, NEB, Parks Canada and the Township of Jasper. The Simpcw FN representative was not able to participate as a member of UC because Highway 5 was closed due to poor weather conditions. While there were two federal entities in UC, Parks Canada acknowledged that the NEB was the lead federal agency. Parks Canada remained in UC to collaborate in decision making and discussion around events that may require them to issue permits for in-park work. Trans Mountain also staffed a Geographic Information System (GIS) unit that produced maps for the area throughout the day. The Status Display Board was kept updated as new events occurred. The Jasper Park Lodge is a pre-identified potential ICP for this area, and a cache of response equipment is kept and maintained in this area. To help inform the response, Trans Mountain staff also used the local Geographical Response Plan (GRP) which had previously been developed for this area as part of Trans Mountain’s GRP development project.Trans Mountain used a format of conducting 'mini meetings' between the official meetings identified in the ICS Planning ‘P’. This was done in order for command staff members to be able to have a brief conversation or seek input / give updates to the Unified Command as events developed. The inclusion of mini meetings was tested by the company to determine efficiencies for command staff to speak with UC members who would generally remain together in a break out room between meetings. The exercise concluded with a tactics meeting.
Observation 5 - Communications
Jasper Park Lodge provided land lines in the ICP, and Trans Mountain staff kept in contact with other exercise participants via cell phone. Trans Mountain field personnel had access to radios with channels 4 and 8 being used to communicate with one another. Trans Mountain staffed the role of Liaison Officer (LO) whose role focused on communicating with the public via social media and traditional media, the activation of Trans Mountain’s Dark Website, notification of impacted or potentially impacted communities and regulators as well as interacting with local media. Parks Canada notified park visitors which areas were off limits, and posted highway closure signs within the park. A communications plan was developed for the exercise and reviewed by UC. Trans Mountain simulated a public communication plan through social media and through outreach with the Township of Jasper. Discussions were held with the IAMC monitors to determine the best method for outreach to Indigenous communities in the area. Parks Canada was also used as a resource for notifying park visitors, and signage was simulated for closure of the highway when it was necessary.A mock media briefing was held with Trans Mountain staff, the NEB, Alberta Health Services and Parks Canada participating in answering questions related to the incident.
Observation 6 - Tactical Response
While the ICP functions were being carried out, Trans Mountain staff executed on-ice response tactics (i.e., drilling) at the company’s Edson facility. Trans Mountain supplied the Geographic Response Plan (GRP) for the area and based its response on the procedures in the GRP. Hot, warm and cold zones were identified, and impacts on Jasper Park, visitors to Jasper Park, the Township of Jasper and downstream communities were all considered.Site security was established at the ICP and at the field location for the benefit of the public and response teams. Trans Mountain’s GRP had a pre-identified control point for capture / recovery of product on the river. Impacts to highways and to CN rail were considered and discussed during the exercise. On ice / under ice recovery was not exercised at this location due to unsafe ice conditions. On ice / under ice recovery was exercised at Trans Mountain’s Edson facility,Air monitoring (both static and roving) was established and Trans Mountain worked with Alberta Health Services to determine drinking water concerns and human health impacts. IAMC monitors participated in this discussion and provided information related to Indigenous communities in the area that withdraw water from creeks.
Observation 7 - Post Exercise
Following the exercise, a debrief was held at the ICP. Exercise participants provided feedback on what worked well and identified areas for improvement. The feedback was documented by Trans Mountain. All ICS documents were turned in to the Records Unit for retention. The following general highlights were noted by NEB Staff:
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
