The DOT / Office of Pipeline Safety requires that OPA90 plans be reviewed at least every 5 years from the date of submission, and that plans be modified and resubmitted within 30 days if any qualifying changes are required (49 CFR 194.121). The original plan submittal deadline was February 18, 1993. Interim approvals until August 18, 1995 were granted to companies that made appropriate certifications (49 CFR 194.119(e)). The original rule was published on January 5, 1993, and was modified on December 24, 1997, and July 13, 1998. An additional rulemaking is anticipated very soon. Indications are that OPS may take enforcement action against companies that are not in compliance with the submittal deadlines and / or have plans that do not reflect current pipeline operations and the current regulatory requirements.

RCP has developed a general interest site for OPA90 planning issues at http://www.opa90.com. Feel free to contact us directly if you require assistance with your OPA90 plan reviews and modifications. Ask for Roger at 225-755-7760.

Help Wanted

Know someone with regulatory expertise who is interested in full or part time work? Our recruiting coordinator would be glad to get their resume! Have them sent to linda@your-rcp.com, or FAX to 713-655-8083.