Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: TransCanada Pipelines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
A field inspection was recommended through the NEB's annual compliance planning to verify the company's liaison and continuing education program through meetings with the company and response parties.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Introductory comments
Date & time of visit: 2018-01-18 08:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
The purpose of the inspection was to assess the implementation and effectiveness of NOVA Gas Transmission Limited (NGTL)’s liaison and continuing education activities as required under sections 33 – 35 of the National Energy Board Onshore Pipeline Regulations. The NEB’s expectations are outlined in the Guidance Notes for the National Energy Board Onshore Pipeline Regulations (OPR) (https://www.neb-one.gc.ca/bts/ctrg/gnnb/nshrppln/gdncntnshrpplnrgltn-eng.html). The geographic scope of the inspection was from Rocky Mountain House, Alberta to Elko, British Columbia.TransCanada PipeLines Limited. (Trans Canada) is the operator of NGTL. Therefore, NEB Staff met with TransCanada staff to discuss how it conducts liaison and continuing education activities on behalf of NGTL. NEB Staff also surveyed and met with relevant municipal fire departments from Clearwater County, Sundre, Cochrane, Turner Valley, Foothills, and Pincher Creek, AB and Elko, BC. Municipal emergency management staff was also present during the Foothills meeting. The information below summarizes this compliance verification activity.
Compliance tool used: No compliance tool used
Observation 2 - Liaison
TransCanada provided information on how it is meeting the requirements outlined in sections 33 and 34 of the OPR requiring a company:
Observation 3 - Continuing Education
TransCanada provided information on how it is meeting the requirements of section 35 of the OPR regarding the need for companies to have a Continuing Education Program that informs first responders, medical facilities and other appropriate organizations and agencies of the location of the pipeline, potential emergency situations involving the pipeline and safety procedures to be followed in the case of emergency.NEB staff note that there is overlap in TransCanada’s liaison and continuing education activities and some of the discussion noted under Liaison is also applicable to the following discussion on Continuing Education.TransCanada discussed how its continuing education program provides information to emergency response stakeholders that have been identified in TransCanada Corporate EM Manual and related specific emergency response plans. TransCanada identifies these stakeholders using 300 m buffer zones on either side of the pipeline right of way for potentially affected public and EPZs for public officials, emergency services, and excavators (construction companies, land developers).TransCanada described the activities undertaken as part of the TransCanada Public Awareness Program to include mail-out brochures and in-person presentations. The presentations occurred on an as-requested basis by a Synergy Group or a member of the Synergy Group. The brochures are distributed annually. The content of the brochure includes natural gas leak detection and immediate steps, TransCanada’s emergency contact number and expectations around equipment, experience and critical functions of emergency officials, actions to avoid during an incident, and TransCanada’s priorities during a pipeline incident.TransCanada said that mail outs are provided to potentially affected public every two years and EPZs are assessed monthly for new landowners who are then sent mail outs. Members of the public residing adjacent to the pipeline can initiate contact with TransCanada to request information through the Public Awareness Program Team, engage directly with TransCanada’s local Land Representatives, or reach out to company representatives at public events.TransCanada described how it measures the effectiveness of its continuing education activities using both quantitative and qualitative methods.Based on the information available to it for the geographic scope of this inspection, NEB staff have not identified any non-compliances with the requirements of section 35 of the OPR regarding TransCanada’s Continuing Education Program.
Observation 4 - Interoperability between TransCanada and those who may be involved in an emergency
TransCanada described how it invites local first responders and municipal officials to EM exercises to test the capabilities of both the company and external agencies to respond to an incident. TransCanada said that the primary role of first responders is scene security and notification to TransCanada in the event of an incident. The primary response to an emergency is conducted by TransCanada using internal capacity and resources.Within the Rocky Mountain Region, TransCanada has conducted 4 full scale exercises since 2015. Within the area assessed for this inspection, the most recent exercise was held in Cochrane in 2018 and prior to that, exercises were held in Cochrane in 2006, Clearwater region in 2010, Crowsnest Pass in 2012 and in Jaffray, BC in 2016. Feedback forms are given to first responders who attend exercises and TransCanada uses feedback received to assess further information sharing and interaction with the first responder agency. Some fire departments that the NEB interacted with noted that they had previously participated in exercise planning with TransCanada and expressed interest in ongoing collaboration with TransCanada in exercise design to facilitate cooperation and learning amongst all parties involved.TransCanada discussed using 911 dispatching systems to communicate with first responders and noted that it is immediate, direct and effective. TransCanada has also shared radios with first responders in the past. TransCanada uses the Incident Command System (ICS) for emergency response and described its ICS training for staff. ICS is also tested during emergency response exercises. TransCanada said that since the ICS is commonly used by public sector emergency services, its use of the same incident response process ensures the terminology and process are the same and if applicable, a unified command can be established to integrate goals and objectives during response. TransCanada noted that exercises provide an opportunity to identify and address any gaps between TransCanada’s plans and municipal and first responder emergency plans.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Please confirm that, one month prior to TransCanada’s 2019 baseline mail out package and questionnaire to emergency response stakeholders, TransCanada will submit to the NEB, a report of liaison and continuing education activities conducted since March 2018 that summarizes:
Due date: 2019-07-01
Date closed: 2019-07-22 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
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