Compliance Programs

RCP has a proven track record of delivering comprehensive, accurate, and user-friendly DOT compliance programs that stand the test of time and hold up under regulatory scrutiny. Our experts are among the most knowledgeable in the industry when it comes to understanding state and federal regulations and interpreting how inspection protocols, advisory bulletins, and enforcement guidelines impact compliance programs. Because of our expertise, RCP is also frequently called upon to review and perform third-party gap assessments of programs under scrutiny by regulators.

Operation and Maintenance

RCP’s comprehensive Operation and Maintenance manuals include both company specific operations and maintenance procedures and forms and/or pipeline-specific operating procedures for transmission, gathering and gas distribution operations. For many clients, separating general operation and maintenance requirements from pipeline specific operating procedures and regulated equipment provides both efficiency and flexibility.

• Company Specific Operation and Maintenance procedures can be used for all pipelines along with all pipeline information listed in the manual and would require revision with purchase or divestiture of a pipeline.
• Pipeline Specific Operating Manuals (PSOM) are written for each independently operated pipeline or pipeline segment which includes operating parameters, construction information and listing of regulated equipment; along with normal, abnormal and emergency operations procedures specific to that pipeline or pipeline segment.

RCP works closely with clients to determine which regulations apply to them and the best way to comply while incorporating any existing company procedures and forms. Training is also available for appropriate personnel on the function and use of the Operation and Maintenance Program including the requirements contained within the program, each individuals responsibilities in using the program to comply with regulation, and suggestions for maintaining compliance.

Control Room Management

RCP takes the guesswork out of Control Room Management (CRM) by offering services which allow operators to develop and/or incorporate the newest regulations an industry practices into their existing regulatory-required processes and procedures (49 CFR 195.402 and 192.605).

RCP’s Control Room Management Plans include procedures to address all elements of the CRM Rule including:

• Compliance Checklists
• Fatigue Management Guidelines
• Fatigue Mitigation Strategies
• Comprehensive Alarm Management Plans
• Shift Change Procedures that include all elements of API RP 1168
• Controller Responsibilities during and post Normal, Abnormal, and Emergency conditions
• Training materials designed to be incorporated into the Control Room environment without disrupting daily workflow.

RCP also performs gap analysis and updates of existing control room management procedures and practices to determine which, if any, elements are missing, in order to help prevent regulatory non-compliance. In addition, RCP will make recommendations for addressing missing or inadequate CRM Plan elements to “close the gap”, such as making sure the CRM Program Manual is integrated with the O&M Manual, Site Specific Procedures, Emergency Response Plans, and Operator Qualification (OQ) program, and in some cases revising those manuals order to be consistent with the CRM Program Manual.

Facility Response Plans and Integrated Contingency Plans

RCP’s expertise is second to none when it comes to developing and updating emergency response plans or performing third party gap assessments for plans under scrutiny by regulators. RCP FRPs and ICPs for both large and small facilities have been accepted by all applicable federal, state and local agencies including the Environmental Protection Agency, U.S. Coast Guard, Bureau of Ocean Energy Management, Regulation and Enforcement and the Department of Transportation / Pipeline and Hazardous Materials Safety Administration.

Operator Qualifications

RCP personnel are experts at identifying covered tasks performed on client pipelines and developing and/or modifying training and evaluation programs, and establishing written Operator Qualification (OQ) programs. RCP Operator Qualification Programs have been audited by the DOT/PHMSA and State agencies with great success and take into consideration our client’s operations and organization structure. RCP also performs Operator Qualification Program gap analysis and recordkeeping audits using the most current federal inspection protocols, and audit assistance, as well as work with clients to ensure that systems are in place to manage ongoing implementation of the OQ Program, including contractor management.

Integrity Management Plans

The long-awaited gas transmission and gathering pipeline, and liquid pipeline rulemakings were published in the Federal Register on October 1, 2019.  These rulemakings address several congressional mandates, dating back to the 2011 reauthorization legislation and addresses several congressional mandates, NTSB and GAO recommendations.  The effective date of the rules is July 1, 2020, with several requirements that extend out as much as 15-20 years to complete.  These are significant rulemakings and RCP can help operators to integrate the new requirements into their integrity management plans.

RCP has extensive experience in all elements of Integrity Management Program development and assessment for both Hazardous Liquid and Natural Gas Transmission and Distribution systems that have successfully completed audits by PHMSA or state agencies and include the following elements:

• Written Procedures and Forms
• Spill Modeling
• HCA Identification and Class Location Analysis
• GIS/Mapping
• Risk Modeling
• Preventive and Mitigative Measures

Public Awareness

Federal pipeline safety regulations require pipeline operators to conduct continuing public awareness programs to provide pipeline safety information to stakeholder audiences, including the affected public, emergency officials, local public officials, and excavators. RCP works with companies to ensure their Public Awareness Program (PAP) complies with all federal requirements in 40 CFR 192.616 and 195.440 as well as API RP 1162 including:

• Program Development
• Program Gap Analysis
• Annual Self-Assessment
• Address Verification Methodology
• Mandated Third Party Effectiveness Evaluations and its Impact on the Operator’s Program

RCP also provides assistance and guidance for Public Awareness Effectiveness Program inspections throughout the entire inspection process including:

• Pre-Inspection Preparation
• Public Awareness Recordkeeping Audit
• Review of Existing Effectiveness Evaluation and Recommendations for Continuous Improvement
• Inspection Support (On-Site Throughout Audit)

Damage Prevention Program

RCP develops Damage Prevention Programs that meet 49 CFR 192.614 and 195.442 “Damage Prevention Program” requirements and include the following elements.

• One Call Response Process Overview
• One Call Screening Guidelines
• New Property Development Information
• Required One Call Documentation
• Third Party Contact Sheet
• Locating Procedures
• Line Marking Procedures
• Excavation/Backfill Procedures
• Excavation Incident Follow-Up Process
• Pending Jobs Procedure
• Training Procedures
• Procedure for Making a One Call Notification

Underwater Inspection Procedures

RCP has subject matter experts for developing or updating comprehensive Underwater Inspection Procedures (UIP) to comply with 49 CFR 192.612 and 49 CFR 195.413, 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 49 CFR 195.2; 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.”
• Reporting and permitting requirements for “exposed underwater pipeline” or “hazard to navigation” pipelines.
• Criteria to determine next depth of cover inspection date. ¹

¹ RCP has developed a Inspection Interval Risk Model (IIRM) to help clients determine next depth to cover inspection dates by ranking external threats and associated consequences such as: third party intervention (such as shipping lanes, anchor patterns, etc.); environmental or natural intervention; pipeline design and installation characteristics; potential HCA impacts; and release history.

Process Safety Management  |  Risk Management Plan

RCP’s experts have been recognized as leading corporate resources on PSM, RMP, ISRS (International Safety Rating System), OSHA safety and security program requirements. This includes working with API to develop PSMS Implementation Tools and guidance documents to assess “conformance” to the RP, a standardized audit process for implementation of the RP, and to evaluate the effectiveness of this RP in improving the safety performance of pipeline operators.

RCP has in-depth knowledge and experience in developing both PSM (OSHA 29 CFR 1910.119) and RMP (EPA 40 CFR part 68) programs as well as conducting program gap analysis and effectiveness evaluations of existing programs against regulatory requirements and industry.

RCP’s experts have been responsible for the success of all facets of the process safety, health & safety, and risk management programs for chemical and petrochemical organizations including global responsibilities for risk management, security, and compliance strategy integration.

Our Certified Safety Professionals have coordinated PSM and RMP compliance for highly hazardous production processes and lead several PSM/RMP compliance audit teams at various facilities throughout the country.

Click here to learn more about RCP’s Process Safety Management.

Spill Prevention Countermeasures and Control

US Environmental Protection Agency (EPA) requires all facilities that use, manage and store oil (1,320 gallons or more) to develop and implement Spill Prevention, Control and Countermeasure (SPCC) Plans. Certain states may have a lower oil storage volume that may trigger a plan.

RCP provides a full range of services for your company’s SPCC Plan and has earned a nationwide reputation for providing high-quality, compliant SPCC Plans to a wide variety of industries. Our senior staff has decades of experience in designing and implementing SPCC Plans with a thorough understanding of the operational and regulatory issues that face our clients.

RCP has completed and certified SPCC Plans for over 200 oil and gas production sites ranging in size from single test vessels to large gas treatment plants, and included both onshore and offshore facilities. These Plans incorporated the numerous requirements contained in the SPCC Rule.

RCP’s lead professionals are heavily involved in industry and agency task forces and committees related to spill planning and emergency response. We can conduct a gap analysis of your current SPCC Plan and provide updates and recommendations based on the SPCC Guidance for Regional Inspectors.

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