what we do
RCP's regulatory interpretations and compliance programs are highly respected throughout the industry
and at all levels of the federal Pipelines and Hazardous Safety Administration, and applicable state
agencies for their regulatory expertise and thoroughness.
Our professional staff has decades of experience in government and industry, and know that regulatory issues
can be complex, confusing, and a strain on resources. We not only understand the regulations, standards, and
engineering requirements behind the rules, but also the federal and state agencies that write and enforce them.
RCP has 20 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 including FAQs, Advisory
Bulletins, and Preambles. 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.
Acquisition Due Diligence
RCP is a valuable resource when it comes to identifying issues important to the acquisition
decision-making process (i.e. "deal-killers", significant compliance gaps, significant future regulatory
liabilities/costs, etc.). RCP will evaluate the pipeline's operating and maintenance history, its
environment, and other factors to identify any unusual risks or liabilities such as problems identified
during previous in-line inspections, which have not been corrected.
RCP has a proven track-record helping clients identify gaps in their compliance programs and conducting mock audits in
preparation for integrated federal and state inspections. RCP's approach to audits and assessments is typically either
consultative or enforcement oriented depending upon the client's needs. The consultative approach provides a gap analysis
on existing compliance programs and management practices versus industry standards and regulations. The enforcement
approach incorporates a mock audit, which gives clients an idea of how well a facility can manage an agency audit and how
likely it would be for an agency inspector to issue a Notice of Violation.
Agency Response Support
RCP provides post-inspection agency response support to help quickly correct any procedural deficiency
and help develop improved implementation methods to address agency inspection closure notes or Notice
of Amendment letters. If there are post-inspection responses or hearings required, RCP is experienced
in guiding companies through the process and preparing effective response strategies to bring outstanding
inspection deficiencies to closure.
RCP’s executives frequently serve as expert witnesses in pipeline litigation cases ranging from small
property damage claims to large complex class action lawsuits. Additional types of litigation support
include interpretation and detailed reports on regulatory compliance determinations, code compliance,
general industry practices, engineering, safety, and risk analyses.
Pipeline Safety Management System
RCP has the expertise and experience helping companies assess, develop and implement safety management
systems. RCP has been heavily involved in API 1173 work groups and “wrote the book” on Pipeline SMS Why,
What and How booklets for the American Petroleum Institute.
RCP offers several public courses throughout the year at our Houston headquarters training facility
which includes our popular DOT Gas and Liquid Pipeline Compliance Course, Pressure Testing Workshops and
NEW Fundamentals of Transmission Pipeline Operations. RCP also provides on-site training for groups of
five or more as well as customized company specific training ranging from half-day refresher courses to
intense interaction three-day sessions.