Frequently-Asked Question FAQ #124

FAQ-124: Timeliness when Specific Timelines are Not Specified

Question: The rule includes many requirements that do not have specified time periods for completion. Examples include gathering and integrating data and information on the entire pipeline, updating risk assessments when the results of assesments are available and identifying HCAs for new pipe. How soon must these actions be completed?

Answer: OPS expects operators to diligently pursue completion of actions required by the rule. At the same time, OPS recognizes that these actions cannot occur immediately. OPS inspectors will assess an operator's plans, actions, and progress to verify that an operator is making a good faith effort to comply.

For immediate repairs, physical remediation may take some time, but should be done promptly. Immediate action is needed, however, to assure safety. OPS expects that actions to reduce pressure or shut in the line will begin as soon as a defect meeting immediate repair criteria is identified.

For the specific example of identifying HCAs for newly-installed pipe, the requirements for newly-identified HCAs apply. Any HCAs on the new pipe must be identified and included in the baseline assessment plan within one year (192.905(c)). These new HCAs must be assessed within ten years from date of installation of the new pipe (192.921(g)).