When it comes to determination of which regulatory agency has jurisdiction over your facilities and assets, we are the experts. If you don't know whether you are regulated, you run the risk of finding out the hard way with little to no time to get into compliance before regulatory agency inspectors show up at your door. On the flip side, you shouldn't spend money and resources for regulations that really do not apply to your facilities. Be fully aware of pending rule changes that could stop your facility in its tracks before it ever begins operation. These are all issues that should be handled by a regulatory specialist.
RCP has years of experience in jurisdictional determination for complex upstream, midstream and downstream facilities. We have extensive
knowledge of the applicable Federal and State regulations, as well as the Letters of Interpretation that may be applicable to each situation.
We can offer clarification of governing regulations in the event of apparent overlapping jurisdiction and specific delineation of regulatory
boundaries - pinpointing specific locations of jurisdictional separation.
RCP documents our opinions and findings in a report that can be used to justify future actions for each facility. Our detailed report and justification clears up any confusion about what is / is not regulated. The findings can be used as a reference if a Federal or State inspector questions what is regulated.
RCP can answer your questions regarding the jurisdictional status related to pipelines
that may be regulated by the Department of Transportation Pipeline and Hazardous Materials
Safety Administration (DOT/PHMSA).
Is there uncertainty as to whether a pipeline meets the applicability of:
- 49 CFR 195 (Transportation of Hazardous Liquids by Pipeline),
- 49 CFR 192 (Transportation of Natural & Other Gas by Pipeline),
- 49 CFR 194 (Response Plans for Onshore Oil Pipelines),
- Interstate versus Intrastate, or
- Breakout Tanks?
- RCP's subject matter experts can review the physical locations of pipeline facilities,
including details of all tie-in points, a pipeline schematic showing connections,
details on pipeline sizes, wall thickness, MAOP, % SMYS and function of the pipelines
and related valves and pumping stations.
U. S. Coast Guard Regulatory Determinations: RCP will assist you in making
regulatory determinations for dock expansions and other specific issues, including
- Extent of USCG Jurisdiction
- Design and Construction Requirements
- Operation and Maintenance Requirements
- Personnel Requirements
- Regulatory Waivers
- Transfer Procedures
- Gulf of Mexico / OCS Platforms
EPA: RCP can develop a complete Integrated Contingency Plan that meets EPA
(40 CFR 112), DOT (49 CFR 194) and USCG (33 CFR 154) requirements. Our previous
experience with contingency plans for both small and large facilities enables us
to be very efficient in this type of plan development.
The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE): Formerly known as the MMS, is the Federal agency that manages the nation's natural gas, oil and other mineral resources on the
outer continental shelf (OCS). RCP has experience in helping pipeline operators with the development of a Plan of Exploration (POE), Development Operations Coordination Document (DOCD); as well as hurricane
and emergency response plans, and Inspection Interval Risk Model (IIRM).
RCP can assist with preparation of waiver / exemption requests to State agencies in the event an operator does operate and / or maintain PHMSA jurisdictional equipment, but circumstances indicate that a waiver from some or all of the compliance requirements may be appropriate.
RCP is your single point of contact for regulatory questions. Our subject matter experts have access to excellent on-line regulatory research systems. This enables us to quickly research regulatory issues, and provide accurate and thorough compliance guidance to our clients.
If an agency inspection identifies deficiencies or in their interpretation of the rules, feel there are some deficiencies, RCP can provide post-inspection support. RCP can quickly correct any procedural deficiency and help develop improved implementation methods to address the agency inspection closure notes or Notice of Amendment letter. If there are post-inspection responses or hearings, RCP is experienced in guiding companies through the process and preparing effective response strategies to bring outstanding inspection deficiencies to closure.