Question: How long does an operator that has had no HCAs, and therefore no integrity management program, have to develop an integrity management program after it discovers a new HCA?
Answer: Section 192.905(c) requires that newly-identified HCAs be incorporated into an operators baseline assessment plan within one year from the date the area is identified. This requirement applies to operators who previously had no HCAs and thus no IM program. They must develop a program, which includes a baseline assessment plan, within one year to address the new areas (and any that may be identified later).
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