Compliance Verification Activity Report: CV2122-320 - TransCanada PipeLines Limited, TransCanada Energy Ltd.


Compliance verification activity type: Emergency Response Exercise

Activity #: CV2122-320
Start date: 2021-10-05
End date: 2021-10-06


Regulated company: TransCanada PipeLines Limited, TransCanada Energy Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):


Rationale and scope:

Verify compliance to the OPR through the evaluation of a Full Scale exercise in the Central Region. This exercise allows CER staff the opportunity to evaluate emergency response capability in each region.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Emergency Response Exercise Evaluation

Date & time of visit: 2022-10-06 16:00

Discipline: Emergency Management




Exercise Planning and Design
Operation Wheat City was a two-day exercise of the TC Energy (TCE) Corporate EM Program based on a simulated security threat and potential pipeline release in TCE’s Central Region.

The Carry the Kettle Nakoda First Nation and the Sioux Valley Dakota Nation were invited to observe the exercise and several external groups representing municipal, provincial, and federal agencies were invited to participate. Private sector stakeholders with potentially impacted local assets or response roles, also participated in the exercise. Participants, including the Canada Energy Regulator (CER), were sent documentation in advance, including a copy of the Exercise Participant Handbook to assist in their preparation for Operation Wheat City.

CER staff were not involved in the planning of the exercise but learned from the company that preparations started several months prior to the activity. The agenda of the two-day exercise was structured to provide participants with a thorough orientation, followed by assignments based on their role in the exercise on both days.  Invited participants included over 130 people and CER staff observed that over 100 were in attendance on MS Teams in the morning on Day One of the event. The afternoon of Day One saw participants split into two groups: one group was responsible for exercising the initial response phase, which included corporate and regional emergency operations centre support, and the other received a refresher on roles within the Incident Command System (ICS) and an orientation on navigation within the MS Teams environment. Day Two of the exercise started with a transfer of command for the company, staff assignments to the response structure, and then continued with the simulated response in the Virtual Incident Command Post (Virtual ICP), interacting with external parties as per the ground rules of the exercise.

The initiating event for the exercise was a security threat culminating in a pipeline release at a meter station, which is a reasonable hazard for the company to simulate. 
The following objectives were set for the exercise:

CER staff recognize that significant planning time went into the event to engage with external stakeholders, to prepare documentation required to support the event and progress play through various challenges, and in the preparation of participants to interact in the Virtual ICP using the technology.  TCE staff indicated that this is the first virtual exercise conducted in their Central Region. CER staff are of the view that there was excellent preparation for the exercise activity as evidenced by the number of external participants that were available and engaged in the exercise, and by the quality of the injects provided to the initial incident responders and the incident management team. There is room for improvement in TCE player preparation as some did not appear to be confident in their assigned role within the incident management structure. 

Exercise Facilitation and Control
The exercise was primarily facilitated by TCE who engaged the contractor NJ Resources for assistance.  NJ Resources provided the MS Teams platform for the event, advance training to navigate the NJ Resources’ MS Teams environment that was built for the VICP, technical support for the VICP, and supported facilitation of the exercise.

Injects, challenges and ground truthing of impacts related to the response were provided to the players through a small team of participants known as the SimCell.  The SimCell, Directing Staff and Coaches were assigned ahead of the exercise and appeared to be sufficient in number for the size of the activity.  CER staff observed that there were responders who felt that some of the information came in later than they were used to.  In future exercises, consider designing the pace of response injects to align more closely with the timing of how events (and information relay) could roll out in an emergency.

CER staff would like to highlight that the orientation session on Day One provided excellent overview of the Company’s expectations of external participants.

On Day Two of the exercise, CER staff requested the company to add two Market Supply Analysts to the NJ Resources Teams platform so they could access the Virtual ICP.  This request was not accommodated.  While CER staff acknowledge there were some technical challenges for the contractor to manage among existing players, evaluators and support staff, a refusal of access to CER staff would not be acceptable in a real event. 
CER staff are aware that TCE also uses MS Teams internally and that there was additional exercise activity that played out within that platform, which the CER did not have access to.  This evaluation is based on observations from interactions observed and files stored in the NJ Resources’ Operation Wheat City Team.

Notification and Reporting
The company uses notification software to facilitate their internal reporting and briefing process.  External notifications to Centra Gas, PMC and Manitoba Hydro were made (with all agencies simulated as being present at the field site).  Through this notification process, they found a couple of contact numbers were outdated. This demonstrates how exercises contribute to emergency preparedness.

The company called the TSB within prescribed notification timelines and later filed an exercise event report using the CER’s online event reporting system (OERS). The preliminary report was followed by an update the following day. Considering that the CER was a member of the Unified Command for this simulated response, event report updates submitted through OERS have the potential to cause confusion if the content of the update does not match the information that the CER IC is relaying to the CER.

During the initial incident response on Day One, the TCE Incident Commander (IC) had directed that a Job Safety Analysis (JSA) be developed prior to entering the site. Mid-way through the exercise on the second day, CER staff observed that only a general JSA was in place.

At 12:15 MT on Day Two of the exercise, more than four hours after activities commenced, CER staff noted there were files uploaded into three of the eleven folders on the Safety Board (fatigue management, safety message – SWO and PPE).  Under the Safety channel, recently edited forms included the 201, the Incident Action Plan (IAP) safety analysis and initial Health and Safety Plan.  The IAP safety analysis had two rows completed: one for meter station and one for the diesel spill.  When the Health and Safety Plan was opened, it was observed to be blank. Considering safety of responders and the public are paramount to any response operation, and additionally considering that documentation was identified as a core component to Operation Wheat City, with a corresponding objective “Participants will follow the ICS documentation and Planning P methodology to manage the incident response” CER staff are of the view that TCE did not meet this objective in a timely fashion from a safety standpoint. 

Response Management
During the initial response phase of the exercise, held on the afternoon of Day One, incident response position and tasks were assigned shortly after the initial incident size-up between the fire department and company responders. Many other agencies were available to play their role in the initial response, including the RCMP, Plains Midstream Canada and Manitoba Conservation. The injects and dialogue between the company and external partners was engaged and productive. Overall, CER staff observed that there was a realistic role play of the responsibilities of the company vis à vis the public safety and protection role of the RCMP and Fire Department.  In addition, it was observed that there was good teamwork among the company players in providing prompts for actions or decisions to be made by the Incident Management Team.

On progression of the incident and briefing of the Regional Emergency Operations Centre (REOC), the decision was made to activate the TCE’s Corporate Emergency Operations Centre (CEOC) in Calgary.  This was appropriate and in line with the company’s criteria for escalation. In addition, the company quickly re-calibrated its response in line with the evolution of the incident, checked in with assigned responders and requested additional personnel to manage incoming resources and perform additional tasks. Division of responsibilities between the field responders (strategic and tactical activities on scene), the REOC (supporting the field responders and preparing for escalation) and CEOC (corporate security engagement for assessment of broader asset impacts) appeared to adhere to the roles identified in the TCE EM Corporate Program Manual.
CER staff are of the view that the exercise objectives relating to the Core Components of Mitigation and Mobilization were effectively achieved on Day One.

On Day Two the exercise began with a repeat of the Transfer of Command Briefing using the ICS201 form. During the handover TCE remarked that the ICS201 form was updated last night and sent to the TCE first responder in the morning.  CER staff checked the SitStat Display-COP channel and observed the completed 201 was not posted there. Finding current and completed documentation was a recurring challenge in the Virtual ICP e.g. at the end of Day One of the exercise, there were no files in the Site Command General channel that were dated the day of the exercise.  A couple hours into the exercise on Day Two, CER staff explored the file folders in various channels of the Virtual ICP, including the SitStat Display – COP channel, to check the incident documentation and found limited updated information. Exercise participants also noted that forms were “all over the place” which leads CER staff to the conclusion that document control was not effective in this simulation. 

Given the exercise was conducted in a virtual environment, with observers, facilitators and evaluators present, it was challenging to identify players in each channel and other controls need to be put in place so that participants are aware of who is in the virtual room and what role they are playing.  No roll call was conducted at the Command and General Staff meetings, going against standard ICS practices. A formal roll call and/or players announcing their arrival and availability during meetings and using colored backgrounds for players (in lieu of ICS vests) are all ways players can be more readily identified in the virtual environment.

On Day Two of the exercise, CER staff observed within the Planning channel that assignments were delegated by the Planning Section Chief and unassigned players communicated their availability for tasking. This was an improvement over Day One.

Visuals in briefings were sometimes out of sync with the common operational picture and there was no use of visuals during some meetings (Tactics and Planning), which made it difficult for realistic player engagement in exercise play. A common operational picture is vital to progressing incident response, in simulation and in real life.

The Liaison Channel and players hosted meetings in an organized and structured manner. Their meetings discussed actions and notifications required, the status of current assignments, and assigned tasks to the Assistant Liaison Officers.

The Liaison Officer expressed the goal to ensure that relevant agencies and stakeholders have contact info for the incident, that they have a way “into” the incident if they want to. CER staff observed a list of section objectives, including their status, and task assignments which were posted in the Liaison Officer Channel.  When not in meeting, notices were broadcast on the general chat to indicate when the next meeting would be. Overall, CER staff observed that the Liaison function was well-managed in the virtual environment. 
The Objectives meeting ran an appropriate length of time, though the players started to drill down into strategies which required guidance from the CER Incident Commander (CER IC) to focus the Unified Command on keeping objectives high level. TCE’s Incident Commander (TCE IC) was new to this position and accepted this and other feedback. The meeting was otherwise effectively led by the TCE IC who continued to communicate regularly with the CER IC throughout the response.

Tactical and Strategic Response
Hot zone and exclusion zones were established rapidly, along with simulated roadblocks to exclude traffic from Highway 10, which meets the access road to the meter station (incident site). The RCMP was engaged in these conversations as they are the authority having jurisdiction for traffic in this area and, more importantly, for the security aspects of this incident as it was suspected to be an intentional disruption.

The CER Incident Commander noted that information was not getting to Unified Command early enough to influence decision-making.  This could be due to slower start of the Operations Section as CER staff observed that they required some facilitator support to advance the exercise. It was not clear to CER Staff that the company was identifying hazards for the tasks they were planning to undertake. Only a generic JSA was developed by Day 2, which was very basic and identified only four steps. The company was not addressing the noise issues or wind direction consideration, yet responders simulated going into the site and closing valves without detailed safety plans.

The company had a post exercise debriefing where the different sections were able to contribute their observations as were participating agencies.  This time felt rushed which, in the CER’s experience, happens often with online exercises. TCE had indicated that this is the first virtual exercise that they have conducted in this region and a learning from this exercise is to allot more time for debriefing to get consensus on the key challenges and best practices, and to provide an opportunity for participants to raise additional observations at the end of the hot wash.

Some players indicated that this large, complex simulation was their first exercise experience.  CER staff advocate for progressively difficult exercise experiences for players, when possible, especially for persons filling key roles in the company’s incident management structure.

Other considerations The company delivered a COVID-19 message to participants, highlighting the reason for conducting this exercise in a virtual format.  Almost all participants were joining from a location where they were working individually, therefore the focus on participant messaging was on disease prevention and stigma associated with COVID-19. Two training sessions (22 and 29 September) were offered to orient participants to navigating and working within the NJ Resources MS Teams exercise environment created for TCE which was called Operation Wheat City Team.  Obtaining access to this Team was vital to participation in this event.  Holding the training sessions in advance provided an opportunity to learn about the structure of the Virtual ICP as well as to troubleshoot connectivity to the contractor’s Teams account.  The pre-exercise briefing on Day One of the exercise also included a quick orientation to NJ Resources’ Operation Wheat City Team and the channel structure used within the Team.  Future exercises held in a virtual or hybrid environment should continue this best practice of introducing players and observers to the platform to be used to reduce frustration and enhance participant skill in navigating channels to find information.

Participants were encouraged to sign-in 30 minutes prior to the start of the exercise on both days to troubleshoot any connection or IT issues.  This proved necessary as some participants had difficulty accessing the Operation Wheat City Team under the NJ Resources account. There were intermittent access and connectivity issues for various participants over the two days. Some of these issues were beyond the capacity of TCE or NJ Resources to address but should be recognized a potential barrier to effective communications which is a risk when managing a response though a virtual environment. 

A weakness in the virtual environment was the difficulty in discerning what members were players and what members were observers.  Players developed workarounds by calling out position names. Creating colored backgrounds or adding IMT titles would mitigate this challenge. In addition, CER staff heard that it was difficult to know what channel to go and when to go there as there were many channels in the Operation Wheat City Team. It was challenging to know which channel was active. NJ Resources suggested that players name meetings to make navigation across the platform easier.

In conclusion, from CER staff observations, TCE’s objectives for this exercise were partly met.  The initial incident mobilization, initial response  and coordination among response partners appeared to work very well.  That said, additional work is needed to prepare TCE staff for engaging in key roles in a full-scale exercise.  This is a recurring observation among three TCE exercises that the CER has evaluated in 2022.  Lastly, the ease of access to information and the availability of up-to-date documentation in the Virtual ICP must be improved for coordinated and effective incident response through the MS Teams platform.  CER staff were unable to determine whether work in some sections of the Incident Management Team didn’t occur, whether it occurred but was not adequately documented or whether it occurred and was documented but was stored outside of the Virtual ICP.


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