When it comes to regulatory compliance, we are the pipeline industry experts. We know how to build customized compliance programs that stand the test of time. RCP can work with you to develop plans that meet all regulatory requirements and internal company policies. RCP compliance programs are completely integrated with one another, including links to regulatory citations, training and qualifications, record keeping forms, and engineering specifications.

RCP provides a full range of regulatory compliance programs for pipelines as well as processing facilities. These programs are just the beginning. Once your program and plans are completed, we continue to be your trusted partner by providing implementation assistance and ongoing support. RCP has the people, the know-how, and the tools to assist you with implementing your programs from start to finish.

• Operations & Maintenance Procedures
  DOT pipelines are required to have Operations & Maintenance (O&M) procedures. These procedures are very comprehensive, regulating the design, construction, operation, maintenance, and emergency response for all regulated pipelines.
  
  RCP's comprehensive DOT Pipeline Compliance Program includes both general and pipeline-specific operating and maintenance procedures and forms. For many clients, dividing the operations and maintenance procedures into general and pipeline-specific information provides both efficiency and flexibility.
  
  
  • The general O&M can be used for all pipelines and would not necessarily require revision with purchase or divestiture of a pipeline.
  • The pipeline specific operating manuals include details related to each section of pipe such as: Normal Operating Procedures, Abnormal Operating Procedures, Emergency Shutdown Procedures, and Normal Operating Condition Charts.
  
  Whether you are developing new manuals or working with existing procedures, RCP can provide procedures and forms in your format or using the RCP System. We have utilized the RCP System for over 100 pipeline operators and have found it widely accepted and most cost effective method of compliance with DOT regulations. RCP can provide training sessions for all appropriate personnel on how the program is formatted, its function, requirements contained within the program, and suggestions for maintaining compliance.
  
  
• Operator Qualification Programs
  RCP can identify the covered tasks performed on your pipeline; develop and/or modify training and evaluation programs; and establish a written qualification program. We can also work with you to ensure that systems are in place to manage ongoing implementation of the OQ Program, including contractors management.
  
  RCP also performs Operator Qualification Program gap analysis and recordkeeping audits using the most current federal inspection protocols.
  
  RCP's Operator Qualification Programs have been audited by OPS and State agencies with great success. RCP also provides audit assistance, if requested.
  
  
• Pipeline Integrity Management
  Hazardous liquid and gas pipeline operators are required to develop and follow an integrity management program for continually assessing pipeline integrity. RCP has the knowledge and experience to provide the optimum solution in meeting these complex requirements.
  
  Whether you operate one pipeline or an extensive network, RCP can assist with the development of a Pipeline Integrity Management plan that satisfies your particular regulatory requirements.
  
  RCP can develop a written integrity management program and support implementation obligations, including the following activities:
  
  
  • Gather Information Necessary for Preparing the Plan – such as maps, material specifications and test records.
    
    
  • Identify and Analyze the Convergence of the Pipeline’s Route with High Consequence Areas (HCA)
    
    • RCP has developed a comprehensive GIS-based overland spill model and air dispersion model that is used to accurately depict the potential impacts of a hazardous liquid release relative to high consequence areas along the pipeline ROW.
    • For gas pipelines, RCP has developed a comprehensive GIS-based process that can accurately depict beginning and ending points of high consequence areas along the pipeline ROW using Method 1 or Method 2 prescribed by the gas IMP regulations.
      
      
  • Complete a Risk Analysis for Each Pipeline Segment in the Plan – a risk analysis is performed by evaluating the threats (such as age, coating condition, new construction near the segment, previous leak history, cathodic protection effectiveness, etc.) to the pipeline segment’s integrity in conjunction with the consequences of a pipeline release or failure. Each segment’s relative risk level is compared to all other segments and all segments are ranked according to relative risk.
    
    
  • Prepare the Written Integrity Management Plan – RCP's Integrity Management Plans meet the DOT/PHMSA requirements by:
    
    • identifying all segments in HCA’s,
    • determining integrity assessment priority,
    • developing a plan for completing all initial assessments (i.e. the “Baseline Assessment Plan”),
    • providing a framework for addressing continual integrity assessment and evaluation including describing measures for evaluating the plan’s effectiveness and listing possible mitigation measures to reduce risks, and
    • identifies recordkeeping requirements and cross references integrity management audit protocols.
      
      
  RCP's integrity management plans have been audited by OPS and State agencies with great success. RCP also provides audit assistance, if requested.
  
  
• Process Safety Management (PSM-RMP)
  RCP has provided Process Safety Management assistance to many industries, and can develop a comprehensive program that can address the following elements:
  
  - Process Safety Information
  - Process Hazard Analysis
  - Operating Procedures
  - Employee Participation
  - Training
  - Contractors
  - Pre-Startup Safety Review
  - Mechanical Integrity
  - Hot Work Permit
  - Management of Change
  - Incident Investigation
  - Emergency Planning and Response
  - Compliance Audits
  
  RCP can also provide the following services:
  
  - an evaluation of the need for a PSM program and an assessment of which individual elements would be most useful to the site if the entire program is not required,
  - an assessment of existing operations to be incorporated into the program (rather than creating a new program), and
  - a training session for all appropriate personnel on how the program is formatted, its function, requirements contained within the program, and suggestions for maintaining compliance.
  
  
• Underwater Inspection
  RCP can develop comprehensive Underwater Inspection Procedures to comply with 49 CFR 192.612 Underwater Inspection and Reburial of Pipelines in the Gulf of Mexico and its Inlets. The procedures include: generally accepted means of identifying water depths as well as pipe burial depths below the underwater natural bottom; criteria to determine whether pipelines being inspected meet the definition of “hazard to navigation” or “exposed underwater pipeline” as defined in 49 CFR 192.2; and, measures that could be taken by operators in the event their pipelines are determined to meet the definition of “hazard to navigation” or “exposed underwater pipeline.”
  
  Underwater Inspection Interval Risk Model
  RCP has developed a risk-based analysis for determining appropriate inspection intervals. The risk analysis method is similar to the process described in the June 1997 Texas Transportation Institute report, Analysis of Pipeline Burial Surveys in the Gulf of Mexico.
  
  RCP will study the specific external threats and consequences associated with the affected pipeline segments. These include third party intervention (such as shipping lanes, anchor patters, etc.); environmental or natural intervention; pipeline design and installation characteristics; potential HCA impacts; and release history.
  
  The Inspection Interval Risk Model package is comprehensive and includes a results summary; a consolidated data summary; a copy of the Inspection Interval Risk Model for each pipeline segment; and, detailed maps that depict the specific aspects of the risk model inputs.
  
  
• Emergency Response
  We have the expertise to update your Facility Response Plan, Integrated Contingency Plan, or Oil Spill Response Plan to include new guidance and lessons learned from recent incidents and natural disasters.
  
  
• Spill Prevention Countermeasures and Control
  RCP has created and/or updated over 200 Spill Prevention Control & Countermeasures Plans. We can conduct a gap analysis of your current SPCC Plan and provide updates and recommendations based on the SPCC Guidance for Regional Inspectors.
  
  
• Public Awareness / Damage Prevention
  RCP can provide a new program, or conduct a gap analysis of your current Public Awareness Program that includes a self assessment. This final product will help you to meet API RP 1162 standards. We can provide turnkey implementation, mail-outs, evaluations, and tracking of your program.
  
  
• Facility Security Plans
  RCP has expertise in performing audits for risk assessments and in developing and implementing Security Plans that are pipeline/facility specific.
  
  The Department of Homeland Security (DHS) issued Final Rule 6 CFR Part 27, Chemical Facility Anti Terrorism Standards, which establishes risk-based performance standards for the security of our Nation's chemical facilities. This regulation became effective June 8, 2007. Chemical facilities are required to prepare Security Vulnerability Assessments, and to develop and implement Site Security Plans.
  
  
• Marine Dock Operations
  
  USCG Facility / Vessel Inspection Programs
  RCP will assist you in developing streamlined inspection programs (SIPs) that meet current USCG policies. We can help you:
  - Develop a company action plan (CAP)
  - Develop vessel action plans
  - Identify appropriate Inspection Criteria References (ICRs) for your vessels
  - Develop appropriate Inspection Schedule and Verification (ISV) forms for your vessels
  - Develop vessel-specific examination checklists
  - Draft correction reports
  - Set up a recordkeeping and monitoring system
  
  Even if you do not participate in the SIP, RCP can assist you in determining applicability of vessel inspection regulations and assist you in monitoring your vessel inspection program.
  
  Preparation and Updating of Plans/Manuals/Forms
  Coast Guard regulations governing Marine Transportation-Related Facilities are rife with paperwork requirements. RCP can provide a very cost-effective solution to the problem of preparation and continuing update of regulatory documents. We have vast experience in the preparation of:
  
  - Dock Operations Manuals
  - MARPOL NLS Instruction Manuals
  - Marine Vapor Control System Operating Manuals
  - Vessel Transfer Procedures
  - Dock Emergency Manuals
  - OPA 90 Plans for Facilities
  - OPA 90 Plans for Vessels
  - Declaration of Inspection Forms
  - Applications for Exemption/Requests for Alternative Methods