Compliance Verification Activity Report: CV2223-235 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-235
Start date: 2022-04-07
End date: 2022-04-11

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: NOVA Gas Transmission Ltd.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

For follow up to INC2022-065

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - CER IC Incident Report

Date & time of visit: 2022-04-10 11:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Report on TransCanada’s Response to the Fox Creek Simonette Road Rupture

CER INC2022-065
CER CV2223-235
Regulated Company: TransCanada Energy (TCE)

Operating Company: Nova Gas Transmission Ltd. (NGTL)
Time of the incident (24-hour clock, including time zone): 03:25 MDT, 7 April 2022
Dates of CER Incident Response: 7 April - 10 April 2022.
The total duration of Incident (if known):
Report Dated: 7 April 2022
Name of Incident: Simonette Road Incident

Executive Summary

This report outlines the Emergency Management actions taken with respect to the TransCanada Energy (TCE) incident at the Simonette Road location, northwest of Fox Creek, Alberta on April 7 2022. This report covers only the Emergency phase of the incident, which occurred from April 7th until April 10th, 2022.  In the early hours of the 7th of April 2022, a third party called 310Fire to report a fireball over NGTL’s Simonette Lateral right of way (RoW) west of Fox Creek AB. TCE Gas Control also noted a high flow/low-pressure alarm on SCADA at 3:25 am. TransCanada Energy (TCE) reported to the TSB that the incident occurred at 03:49 MST. 
The size of the pipeline hole was unclear but there was an approximately 5m x 5m crater seen from an overflight and a large 200 m x 500 m area of the right of way burnt from the resulting plume ignition and fire. The fire also burnt through ATCO powerline posts and lines, resulting in power outages for approximately 50 people downstream. The line was shut in by the control center via upstream and downstream valves and the fire burnt down until the gas in the line was diminished. Vapour monitoring was set at an initial distance of 800 m radius on the morning of 7 April and reduced to 200 m radius by the afternoon with no vapours found present. There appeared to be no direct impacts on wildlife or waterways due to this event at the time of this report. There were some impacts to local infrastructure with ATCO powerlines and multiple other pipelines sharing the same right of way.     
 
Call-outs and information gathering began in the morning hours after the incident. The CER On Call Responder (OCR) began email and phone notifications at 4:40 on 7 April 2022.  CER formed an Incident Management Team of Inspection Officers and notified them early the morning of 7 April. The team deployed at approximately 10:00 on 7 April and began driving to the site from various locations within Alberta. The first CER IO was on the scene of the incident at 18:30 on 7 April. CER staff followed the CER Field Deployment Operational Guide, which included a health self-assessment and criteria for self-quarantine if symptoms of Covid-19 presented either during or after the deployment. Staff deployed with standard Personal Protective Equipment (PPE) (fire retardant coveralls, steel toe boots, hard hat, gloves, eye protection, and hearing protection) as well as communicable disease prevention kits (hand sanitizer, N-95 face masks, Lysol wipes). Covid-19 PPE was also available throughout the Incident Command Post (ICP), provided by TransCanada.

The CER Emergency Management (EM) Inspection Officer participated at the initial ICP at the Latour Camp on the evening of 7 April 2022 and entered into a Unified Command (UC) with the TCE Incident Commander. Additional CER staff members were deployed from Calgary to assist with safety and integrity operations.  The Transportation Safety Board (TSB) also dispatched two personnel to investigate and were assisted by CER integrity staff. CER safety staff observed the field site location to ensure safety considerations were being addressed during all operations.
 
At 3:25 MDT TCE Gas Control noticed a high flow/low-pressure warning at Deep Valley Creek Sales Meter Station. Gas Control dispatched an on-call tech to the site. At 3:49 TCE was notified by Alberta wildfire (who was contacted via their 310FIRE line) of a large fire present on the right of way the Simonette Lateral pipeline occupied.  Three TCE technicians were dispatched by 4:07 and all three confirmed a rupture and fireball and assumed it was on the 8” Simonette Lateral line.

On confirmation of the incident, TCE began isolating the line, shut down the Keyera Simonette Gas Plant at the site, and began their regulatory notifications to potentially impacted communities and customers and supplying response resources to the incident site. 

TCE set up an Incident Command Post (ICP) initially at the TCE first responder’s truck on the side of the Simonette roadway in the early morning hours of 7 April 2022. The ERP was activated, and the emergency planning zone (EPZ) was set at an 800 m radius around the incident site. The area was very remote and took most of the day for deployed responders from TCE and the CER to reach the initial ICP. During this time the area was blocked off via roadblocks and air monitoring was conducted by TCE air monitors. By the afternoon of the 7 April, the EPZ was reduced to 200 m around the incident site based on air monitoring results and a helicopter overflight reported the line appeared to have burned down, there were no secondary fires, no injuries/personnel at the site, and a “truck-sized” hole on top of the pipeline in the right of way.

Upon the arrival of the senior TCE incident commander and CER incident commander at the ICP at 18:30, the decision was made, based on air monitoring and zero LEL levels present, to reduce the EPZ to 80 m and to open up the vital Simonette Road again to controlled traffic. Warning signs were deployed at the edge of the EPZ and roadblocks were in place for the night shift with air monitoring continuing. The ICP was then moved to the Latour Camp and staffed as TCE personnel arrived on April 7th and 8th.

The ICP was staffed with trained and experienced personnel as they arrived and the positions of Safety Officer, Public Information Officer, Liaison Officer, Planning Section Chief, Logistics Section Chief, and Operations Section Chief were staffed right away.

The initial focus and priorities of the response were on responder and public safety. The situation was handled with necessary caution to protect the public and responders via delineating hazard zones, strict PPE requirements, and continuous air monitoring. The initial response actions were conducted per TCE’s Emergency Response Plan. 
  7 April 2020: CER Inspection Officer arrived at the Simonette ICP at 18:30. Staff signed in to the ICP and reviewed Covid-19 precautions in place at the ICP that included personal distancing, access to hand sanitizer, and masks. There was a lot of wildlife on the road so all traffic was warned to drive with caution to the ICP.

CER staff noted roadblock kits were deployed and gas monitors on all TCE employees present. TCE appeared to have good control of the road and stopped people from entering the now 200 m EPZ. TC staff were wearing standard PPE (hard hats, boots, glasses, coveralls), no ICS vests at present, and no masks being worn (however staff were all outside and distanced).

CER staff were then given a briefing on the current situation: no injuries were reported, the line had self-extinguished, no secondary fires were noted, and ongoing air monitoring was being carried out. The incident site was beginning to stabilize as the pipeline was shut down and no longer releasing product. An overflight had revealed a “truck-sized” hole on the RoW, it was unknown if other lines were impacted yet, ATCO had lines burnt through with power out to 50 customers, and 5 First Nations Groups and 1 Trapper in the area were notified of the incident. The incident was classified as a Level 1, as per TransCanada Energy’s Emergency Response Plan. ATCO had also requested to repair their lines on the morning of April 8th, but TCE would not allow this at this time for safety reasons.

CER staff and the TCE Incident Commander established a Unified Command (UC) and agreed to move the ICP to the Latour Camp further away from the incident site. The camp could also provide accommodation, food, and facilities for the coming days. TCE made arrangements with both the Latour camp and Latornell camp to host incident attendees for the duration of the incident. TC field staff were not aware the Transportation Safety Board (TSB) was responding but were informed by the CER IC and made aware that they will want the site frozen for potential investigation once deemed safe.

CER staff followed the convoy to the Latour Camp and drove nearby the incident site at 19:00. They noticed the incident site was very remote with no residences nearby, large powerlines overhead on the RoW, a river downhill from the line, and surrounded by spruce trees. The road itself is radio-controlled, very rough and muddy, and very busy with heavy oilfield traffic use. The incident site looked blackened and burnt along RoW, with smouldering power poles, power lines resting near the ground, and soil debris around the hole. (CER staff were unable to get closer than approx. 100 m, staying on the roadway, so were unable to see the crater directly).

TCE staff discussed mobilizing more equipment at the Latour Camp for the morning and a night crew was selected to keep watch of the site and ensure no entry or disruption. The TCE IC requested copies of the ICS 201, the Job Safety Analysis (JSA), and a product SDS for the CER IC to review. The UC decided to meet at 7:00 April 8th to discuss the next days’ steps and organize prior to the ICP kick-off meeting at 8:00, followed by a Regional Emergency Operations Center (REOC) update meeting.

Two additional CER field staff stopped in Fox Creek to spend the night after a long day of driving and due to the poor night-time road conditions on Simonette Road.

The CER IC met with and updated the CER Field Response Team support staff who were excellent for information sharing, logistics, and communications during the deployment.

 8 April 2022
UC met at 7:00 to discuss any changes overnight, the arrival of additional CER/TCE staff to the site and ICP, and the objectives for the day. The objectives were:
8:00 ICP morning briefing was held with UC, command, and general staff, as well as field staff (prior to them deploying to the site area). The weather was predicting rain and wind which would make the roadway muddy and slick.
Safety Officer update included: The rest of the briefing discussed that the site is an investigation scene so be mindful if entering to not touch or disturb anything, there are no environmental impacts known at this time aside from some trees burnt up during the rupture, and there was a flare up fire on one tree last night from the residual heat in the soil but no additional gas/pipeline leaks or vapours.

ATCO was still asking to repair their poles and lines as soon as possible, which TCE would not allow until the TSB and CER would allow it. It was also determined that I3 had three lines in the RoW but believed their closest line, a 4” abandoned line, was the closest of their lines and wanted to visually confirm no damage. They had three lines in the RoW and Energy Transfer Canada had one fibreglass line.

The Operations section was determining a staging area that morning for site attendees, continued site check-in/out, continuous vapour monitoring, fire watch, and ensured the site remains untouched.

The Planning and Logistics sections set up a schedule for ICP meetings that morning and confirmed IMT roles in the Org chart were on display, deployed more ICP equipment as needed, and distributed ICS vests and equipment that arrived at the camp in the ICP trailer the previous night. Environment specialists were assessing any potential impacts or areas of concern.

The Liaison Officer (LO) and Public Information Officer (PIO) worked with external agencies to notify and keep them informed of the situation, and there had been no media requests or attention to date. All 5 First Nations identified in the area confirmed they were notified of the incident and did not require anything from TCE.

The two CER staff and two TSB staff arrived at the incident site the morning of April 8th and deployed straight to the site (the ICP was further to drive to on the radio-controlled road) after discussing plans with the CER IC.

In the ICP, a meeting schedule was set for the day to include the objectives, planning and tactics meetings, as well as briefings at the start and close of each day. The operational period was set for 24hrs 7:00-7:00 and the incident status board was posted and included a 201, 208, weather forecast, pictures, meeting schedule, and Organization Chart.

CER staff noted the response was very safety orientated with an experienced Safety Officer creating JSAs and ICS safety plans throughout the day. The site itself had a less experienced assistant safety officer present, however, they were well-informed by the SO and CER safety specialist. Safety orientations were prepared for the site and JSAs were done at the site to capture true conditions.

UC decided to continue doing ICS 201 updates instead of a full IAP due to limited staffing numbers created by the scale of the incident and remoteness and general hazard of accessing the ICP if not entirely necessary. The CER staff noted that the scale of the response was appropriate to the scale of the threat or impact and that reasonableness was applied to all aspects of the response; actions were deliberate and well thought out and personal safety remained the top priority.

CER safety and integrity staff at the field site gave feedback to TCE staff to help improve site staging safety and establish a single point of contact and authority at the site. Alternate staging areas were located and a Site Operations Deputy assigned to be the lead of the field site.

TCE used existing relationships in the area to leverage assistance for dust control, restrooms, security, and other equipment, as well as field observers. Resource planning was the top consideration to ensure regular shift changes and seamless coverage for roles. There was excellent communication between the CER staff and ICP staff, as well as in UC.

To allow TSB/CER access, the EPZ remained at 80 m but could be reduced to 25 m to allow for visual inspection with continuous air monitoring and safety personnel accompanying agency personnel. This was also utilized for line locates, ATCO, I3, and TC repair groups. A specific JSA was developed for this procedure. Muster stations and safety supplies were set up at the 80 m warm zone edge, with flagging and cones at the 25 m hot zone edge.

ATCO was able to assess their impacts and begin organizing their repair work for as soon as they were permitted, and line locates were completed and helped determine impacts to other lines.  

The line expulsion of 6 km of the Simonette pipeline was planned for the day to ensure the line had no more vapours inside, however, due to the rising water level in the crater hole, this was not possible. A new plan was developed to wait for vac trucks and pumps to remove water on the morning of April 9th to expose the line and then expulsion could go ahead and take approximately 3 hours.

In the afternoon, TCE (with help from CER and TSB) conducted a sweep of the RoW hillside to look for debris; no fragments were found. The warm zone was cleared and ATCO was allowed to repair one of two burnt lines to return service to customers. The second ATCO line remained down as it extended over the hot zone. The water in the crater was also sampled to test for contaminants.
TCE confirmed with staff that all downstream customers of the methane line have been notified and alternate sources have been located for them to minimize or negate all impacts to them.  

Overnight the water level in the crater will be monitored for spillover and spill containment set up for contingency, as well as wildlife fencing and flagging to deter wildlife. Security and two technicians would remain on site overnight and monitor the air for gasses.

UC decided that the incident remained at level 1 emergency. The emergency phase will be declared over when line expulsion is completed and the TSB investigation is over or they release the site.  

9 April 2022

UC met at 7:00 to review potential issues, overnight occurrences, and any changes to the situation. Potential issues arising include the increasing rainfall that may impact the ability to pump out the crater efficiently and safely as the slope is muddy and soft due to ground water. Additionally, any bubbling in the crater water may indicate gas release and that danger is still present – none had been noted yet. The water sample from the crater did show low levels of contaminants, which meant water could not be pumped out and released, but would have to be transported away for appropriate disposal.

UC hosted the morning briefing at 7:00 and set Objectives for the day which included:  ICP visual aids and field site check-in/out process improved. CER staff heard discussions of and saw work on ICS 204 tasking, 234 tracking forms, and demobilization parameters and planning beginning.

TCE was made aware via line locate results that there was a buried ATCO powerline in the RoW and concerns were raised over knowing if that line was live or not. Work at the site was halted near the line and the TCE Deputy Incident Commander sought clarity. He was able to find out the line was a portion of the existing overhead line system, buried in one area, and thus confirmed not live and no hazard was posed, but considered for future ground disturbance work.

An Environmental plan was created by TCE staff in Calgary, UC looked at the plan and high level, approved it. Confirmed that TCE had hired a technician for the site to manage wildlife fencing and plans.  Sorbent boom was ascertained by nearby oil and gas operators, which showed good cooperation and creative thinking and was put in place around the crater to absorb any contaminants should the water breach the top of the crater.

The vac trucks began slowly pumping out water from the crater, which took much longer than anticipated. CER and TSB staff oversaw these operations and were eventually able to see the pipeline. Removal of the water also removed the hazard of contaminated water spillover from the crater and into downstream waterways.

UC began discussing transferring from a UC to a single TCE command and transitioning from the emergency phase to the repair and recovery phase. The Transfer of Command from UC to single IC reasoning and qualifiers were agreed to as follows:
UC decided to transfer command to a single TCE IC and did so at 17:00 9 April 2022. The CER IC was able to convoy out on the controlled roads with the last crew of the day at 19:00. The CER safety and integrity specialists would remain at the site location for an additional day to oversee the transition from emergency phase to recovery and repair phase on April 10th.
  TransCanada – Accepted their role as Responsible Party. TC staffed its ICP and field operations assignments with experienced, trained personnel, as well as new staff to shadow roles. All relevant ICS positions were filled, which took time to staff due to the remote location and access issues to the incident site.
Canada Energy Regulator – CER staff responded to this incident from the receipt of the report from the On-Call Responder and on-site through the emergency phase lasting from 18:30 7 April 2022 to 17:00 on 9 April 2022.  CER staff joined in Unified Command as the federal Incident Commander, and in the field as Safety IO and Integrity IO.
Transportation Safety Board (TSB) – TSB sent two inspectors upon notification of the incident. The inspectors attended the incident site during the second day of the field response on 8 April 2022. TSB has opened an investigation on this incident. 5 First Nation groups were notified of the incident, as well as 2 additional Metis groups due to proximatey to traditional use areas. 

Members from a notified First Nation group were hired as certified fallers to attend the incident site and cut down burnt-out trees at risk of falling; they conducted this work on April 9th.

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