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TVC Documentation for PHMSA’s Gas Mega Rule

PHMSA's Gas Mega Rule uses the phrase “traceable, verifiable, and complete” when referring to compliance records to support established MAOP/MOP and related procedures. However, some operators are struggling to know when they’ve met those conditions—and thereby how to know when they are in compliance.

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The Pipeline Hazardous Material & Safety Administration (PHMSA) released what has become known as the Gas Mega Rule due to its size and implications on gas pipeline operations. Published in 2019, the regulation went into effect this month with rolling deadlines for subsections, and despite the enormity of the regulation after eight years of research and drafting, some aspects stood out to operators as unclear. Specifically, PHMSA uses the phrase “traceable, verifiable, and complete” when referring to compliance records to support established MAOP/MOP and related procedures. However, some operators are struggling to know when they’ve met those conditions—and thereby how to know when they are in compliance.

Documentation from 2011 to Now

In 2011, PHMSA released a notice that addressed, among other items, establishing MAOP and MOP with record evidence. The notice stated that, for data to be considered accurate in support of compliance, it must be “traceable, verifiable, and complete.” While the terms are commonplace, how they were proven to be achieved via documentation was not easily defined, leading PHMSA to release a second notice in 2012, titled “Pipeline Safety: Verification of Records,” which guides operators on the characteristics of documentation that can be used to show compliance. While the phrasing is used to address establishing and supporting MAOP/MOP, the concept is gaining traction as being applicable to all compliance records. The terms have not yet been applied to compliance documentation across the board; however, it is not unlikely that PHMSA will eventually set an expectation for all compliance records that follows suit. In that case, in addition to operators understanding how to achieve traceable, verifiable, and complete (TVC) records for MAOP/MOP, it will do well for all operators to begin applying the TVC principle on all compliance records.

Defining TVC Terms

According to PHMSA, traceable records “are those which can be clearly linked to original information about a pipeline segment or facility.” In other words, a paper trail exists that establishes how the information can be considered original. Common examples are as-built documentation, purchase requisition, and initial testing results. For newer construction, this is often achieved easily via digital records; however, it becomes complicated for operators of older assets. Pipelines that were built in the 1990s or earlier are likely to have printed records, with the mid-century files often stored in file cabinets. Despite their age, these records must be made available if they are the only records showing the original information, in which case digitization is recommended for complete recordkeeping. Additionally, operators must be mindful of records that have been transcribed from the original documentation. Errors can occur during the transcribing process, so PHMSA recommends that operators verify the information with or make available for future verification complementary or supporting documentation.

Verifiable records are those that can be “confirmed by other complementary but separate documentation.” The responsibility of verifying records falls on operators, which means they must be able to prove that the information contained within the documentation is correct. In some cases, this is possible via supporting information, such as with test results that support a report or a purchase order that contains item specifications; however, some cases are not as easily verifiable. Test results, for example, can only be verified by the individuals who performed the test, in which case it is likely a vendor’s documentation comes into play. In this regard, PHMSA states that affidavits are generally only acceptable as complementary documentation if they are “prepared and signed at the time of the test or inspection by an individual who would have reason to be familiar with the test or inspection.” In other words, if the affidavit was not completed at the time of the test, it is generally not accepted as verification.

Complete records are those that show documentation has been “finalized as evidence by a signature, date or other appropriate marking.” Obviously how the documentation is completed is a matter of the type of record, but all records should have a method of approval or sign-off to validate their information. Ensuring this process is completed is essential for proper compliance recordkeeping. However, complete has two definitions based on the example provided by PHMSA. Their example of a complete records is a pressure testing record that identifies the specific pipe segment that was tested, the information for who tested the pipe, the testing duration, and applicable information such as test medium and temperatures, accurate pressure readings, and elevation information. While each of those items is a separate piece of testing information, the record is not complete without the entirety of the information. Therefore, a complete record must not only contain all of the relevant information but be designated in some way as having a processed finished, such as by signature.

Defining What TVC Means for You as an Operator

Operators must remember that, while TVC recordkeeping often bring to mind MAOP/MOP compliance, as a principle of documentation, it is best to apply it whenever possible. Well-meaning operators can find themselves in hot water if they produce records that are incomplete, lack verification, or cannot be traced to the original documentation, even outside of MAOP/MOP requirements. That is why it is significant for operators to familiarize themselves with the concept of TVC and define for them what that means within their own recordkeeping procedures. Many will find that it is a matter of reviewing documentation to identify and address gaps in information—something that should be part of annual compliance review—but others will discover that it requires documentation processes to consistently produce TVC documentation as operations continue. Whatever the method for getting there, operators will find that ensuring recordkeeping follows TVC principles will assist in every audit, regardless of the topic.

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Whitney Vandiver Ph.D.

Whitney Vandiver Ph.D.

Pipeline Compliance Specialist & Thought Leader, NuGen Automation

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