Will operators need to seek waivers from PHMSA Pipeline Safety in order to change assessment schedules after the initial Baseline Assessment Plan has been developed?
No. PHMSA Pipeline Safety 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 operators 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. Assessment plans are likely to change, and 195.452 (c) (2) requires operators to document the basis for changes in the plan 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
Related Questions
- Will operators need to seek waivers from PHMSA Pipeline Safety in order to change assessment schedules after the initial Baseline Assessment Plan has been developed?
- Should operators archive previous versions of their assessment plans so PHMSA Pipeline Safety can track changes to these plans over time?
- What specificity does PHMSA Pipeline Safety expect for schedules in baseline assessment plans?
