Natural Gas Case Study: Ensuring Emergent Compliance

SCOPE: Our valued client is a S&P 500 natural gas company, the USA’s largest natural gas-only distributor that safely delivers reliable and efficient natural gas to more than 3 million distribution customers in over 1,400 communities across eight states. The company focuses on storage and compression facilities and was tasked by the Railroad Commission of Texas (RRC) to submit an Emergency Operations Plan (EOP) by August 1, 2022. The RRC provided an outline for the content of the first three (3) sections of the EOP.

SPARK THOUGHT was tasked to rework their facility-based Emergency Operations Plans (EOPs). This work included creating and revising content and structure to incorporate the RRC EOP structure and content. A gap analysis was conducted between the RRC EOP structure and a current company EOP draft. We conducted a discovery workshop to discuss gap analysis findings and to address the gaps between their current EOP compliance state and their desired RRC EOP compliance state.

PLAN: Our Regulatory Compliance and Technical Documentation Specialists expedited a path forward with a plan ensuring full compliance with the RRC EOP structure and content requirements by an immediate deadline. This plan also addressed facility-specific EOP revision needs and flexible client-collaborative workshop times respecting the client’s schedule and input.

ACTION: We took timely action to restructure the company’s EOP draft based on the RRC EOP guidelines. Some important actions taken were:

1. Thoroughly researching the RRC EOP requirements to ensure full compliance of the client’s facility EOP
2. Creating a working draft of the facility EOP including research and revisions discussed in the discovery workshop within an expedited timeframe to meet the RRC deadline
3. Coordinating collaboration between the client and Spark Thought on the facility EOP draft then implementing subsequent revisions based on client’s comments before the second workshop
4. Scheduling and conducting a follow-up, two-hour EOP workshop that respected the client’s schedule and the RRC time-sensitive window to discuss revisions and revised structure
5. Delivering a near-final draft of the facility EOP including revisions discussed in the second workshop to all client workshop participants within an expedited timeframe to meet the RRC deadline
6. Capturing and implementing final input from the client and delivering a final content draft of the reworked, compliant facility EOP within the RRC timeline

REVIEW: We used our five-point project review and delivery check on our documentation solution including:

1. Verifying that all client’s EOP content creation and revision needs were met through rigorous content and structure reviews
2. Evaluating the degree to which our documentation solution met our client’s needs by scheduling a review with the Vice President of Operations and gathering final revisions
3. Resolving any remaining gaps in our solution to ensure thorough compliance with the client’s requests and the RRC EOP content outline
4. Refining overall quality of documentation and related materials created through our final review process
5. Ensuring on-time final product delivery to meet client’s RRC deadline

KNOWLEDGE: SPARK THOUGHT delivered a final facility EOP that met all client restructuring needs based on the structure suggested in the RRC’s EOP memo. In doing so, we also added sections not previously addressed in the EOP and revised wording provided by the company to improve the content’s readability.

This facility EOP is just the beginning. Our client is confident in the knowledge that the newly added EOP revisions will make the company audit ready. They trust our skill in making content more explicitly compliant, more thorough, and easier to navigate which has resulted in the client using this revised EOP content as a template to be used in all company storage and compression facility EOPs. Beyond this, our client trusts Spark Thought’s thorough tracking of ongoing changes in federal and state oil and gas regulations and knows we will be there to help them navigate all changes necessary in a thorough, clear, and timely manner.

SPARK THOUGHT has broad experience helping major organizations and corporations assess regulatory compliance needs and implement frameworks that are customized to address their specific needs. We have performed regulatory compliance gap analyses for oil and gas companies, created written procedures to cover new regulations, designed new forms and records management processes, assisted with preparation for government audits, and generated course materials for compliance training.

We listen. We collaborate and innovate. We deliver customized Knowledge Management Solutions.

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