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The Problem/Approach:
After passage of the Part 192 mega rule, many pipeline operators understood they needed to not only develop a plan for compliance with the new regulation, but they also needed to begin the process of gathering their records to understand where their traceable, verifiable, and complete (TVC) data gaps existed. Based on the gap analysis of where records did not exist for the TVC compliance, gathering the necessary information could become a very long process. Hence, starting on building their TVC data took on added consequences. Several of these companies asked Integrity EPC (IEPC) to develop and lead their process in performing the records search and gap analysis. 

The Execution:
Because each pipeline operator has records in different states of availability, IEPC meets with each operator to understand their situation and develop processes to accomplish the end goal. This operator had records in their GIS, with some of the data having the necessary references to the document which had various states of TVC, while many of the records had not been added to the GIS and still resided on paper. IEPC developed the process by first reviewing the GIS and determining a gap analysis on this data, by working foot by foot along each pipeline. This data gap was then used to search through the paper records to find the missing information. When a record containing missing TVC data was found, the document was scanned and put into a document management system for ease in linkage from the GIS. As the missing information was identified, the data was entered into their GIS with links to the document management system. The paper records were stored in five different locations, requiring our team of two analysts to travel to each location with a portable scanner and portable hot spot, so scanning and linkage to the document management could be performed on site.
Conclusion:
After completion of the record search, a final report was completed with a summary of missing items and plans on how to close these gaps were presented to the operator. The operator is now in the process of instituting the IEPC recommendations on closing their TVC data gaps. IEPC is engaged in working with the operator on implementing this plan. Due to the operator instituting the plan provided by IEPC, the operator is well ahead of schedule in completion of these tasks before they are required to be completed and able to plan judiciously for the years ahead for budget purposes.

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