The TVC process brings confidence that pipeline records are:
- Traceable: Records can be clearly linked to original information about the pipeline
- Verifiable: Information is confirmed by other complementary but separate documentation
- Complete: Record is finalized as evidenced by signature, date, or other appropriate marking
Advisory Bulletin ADB-2012-06, PHMSA
Some pipeline system operators struggle to understand or implement the full extent of the traceable, verifiable, and complete (TVC) rules initially introduced by PHMSA in an Advisory Bulletin in 2012 and further developed as 49 CFR192.607 in the recently adopted gas rules in 2020. Combined with the requirements for maximum allowable operating pressure (MAOP) reconfirmation, some operators may be faced with inadequate procedures or incomplete data to become compliant.
G2-IS has many years of experience investigating and reviewing pipeline and facility records. As a result, the G2-IS engineering, asset integrity, and regulatory compliance teams have developed appropriate technology, processes, and procedures to help operators achieve compliance with federal, state, and local rules and regulations.
G2-IS experts work with operators to determine current TVC procedures and then tailor the comprehensive G2-IS TVC approach to that of the client. The G2-IS team has developed a unique matrix approach to locate TVC records, using a rigorous systematic assessment to identify and spatially locate each linear foot of pipe and pipeline components. In turn, G2-IS can help determine whether material records exist for each of the four material attributes required: outside diameter, wall thickness, grade, and seam.
G2-IS applies a comprehensive method for TVC of records that covers the following main process areas:
- Data discovery & review: Initiates data assessment and definition of a framework to determine the systems and records quality and availability as well as the program’s scope of work.
- Record quality determination: Guides a customer-specific discussion with the proper stakeholders (record and system owners) to assess individual systems and determine the quality and level of confidence of records on those systems.
- Records governance: Establishes an agreed-upon approach to “TVC” a system, with the proper application of the record matrix: defining completeness verification, confidence level, and quality determination grading.
- Mitigation: Defines the approach to resolve TVC gaps by addressing two areas:
- Regulatory compliance: Plan to mitigate record gaps in the context of keeping compliance with regulations.
- Safety: Approach to determine MAOP for gap segments using default values.
This framework creates the structure to build a Pipeline Feature List (PFL) to bring all data and values together and allow for proper documentation of total TVC efforts covering all the assets and pipeline length.
An integrated team at G2-IS offers unparalleled expertise in helping oil and gas operators navigate the challenges of locating and validating TVC records to meet the code requirements of today’s gas and liquids rules. Key elements of this program include:
- TVC determination process: Implement cost-effective TVC methods for a specific system or enterprise.
- Database and PFL: Using proprietary technology, enable a robust digital PFL with all the appropriate records, including data views, reporting, and dashboards.
- Additional support: Consult on identifying issues and gaps, recommend resolution, and formulate a planned approach on prioritized mitigation to ensure all required assets are TVC.