Section 192.925(b)(3)(iii) requires notification procedures for any changes to my ECDA plan. Does this mean I have to notify OPS every time my plan changes?
No. The notification required in 192.925(b)(3)(iii) refers to assuring that company, and contractor, personnel involved in planning and performing ECDA are aware of changes in the ECDA plan. OPS need not be notified unless the changes substantially affect the total IM program’s implementation or significantly modify an operator’s overall IM program or the schedule for carrying out program elements (192.909(b)). Changes in the plans to conduct ECDA direct assessments on specific covered segments would not meet this threshold.
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- Section 192.925(b)(3)(iii) requires notification procedures for any changes to my ECDA plan. Does this mean I have to notify OPS every time my plan changes?
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