Frequently-Asked Question FAQ #10

FAQ-10: Inheritance of Plans and Deadlines

Question: If a pipeline subject to 192 Subpart O is sold, does the new operator "inherit" integrity management plans and deadlines from the original operator?

Answer: The regulatory deadlines for assessments (e.g., that re-assessments be conducted within specified intervals, based on operating stress levels) continue to apply, as well as the schedule requirements for any remediation required by 192.933 that may be pending at the time ownership of the pipeline is transferred. Compliance deadlines established in 192 Subpart O for identifying segments in HCAs and for completing 50% or 100% of Baseline Assessments continue to apply. For purposes of integrity management, an operator acquiring a pipeline would be expected to integrate that pipeline into its integrity management program. OPS would expect this integration to occur within one year. Integration of new assets into existing Baseline Assessment Plans may result in realigning schedules for future assessments based on the relative risk of the acquired pipeline and the operator’s existing pipeline(s).

Integration of acquired pipe into an operator's IM plan could constitute the kind of substantial change in the IM program for which notification is required under 192.909(b), if the integration caused significant changes to existing schedules and programs.