Will operators need to seek waivers from OPS in order to change assessment schedules after the initial Baseline Assessment Plan has been developed?
No. OPS understands that there are a number of factors that could result in the need to modify Baseline Assessment Plans after their initial preparation. For example, as information is obtained from the initial integrity assessments, risk analysis, and operating experience, an operator s understanding about the specific integrity threats and relative importance of those threats may change. An operator may elect to apply a different integrity assessment method (e.g., select a different in-line inspection tool that may improve the capability to detect a particular type of defect), or perhaps accelerate assessments in some areas because the risks are higher than previously understood. Because assessment plans are likely to change, OPS expects operators to document the basis for changes in the plan (required by 192.909(a)) so these can be reviewed during inspections. It is not necessary to apply for a waiver to change the Baseline Assessment Plan. Even though an operator’s plan may change,
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