On August 15, John Erickson spoke on behalf of the APGA Security and Integrity Foundation (SIF) at the Midwest Energy Association’s Operations Conference in Rochester, Minn. John focused on lessons learned after eight years of complying with the Distribution Integrity Management Programs (DIMP) regulation. Over 1,600 distribution operators have used the SIF’s Simple Handy Risk-based Integrity Management Plan (SHRIMP) program to develop their DIMP plans. John’s talk was based on feedback received from SHRIMP users and state regulators who have audited systems using SHRIMP.
One overriding lesson learned is that many operators don’t fully understand the concept of integrity management. Integrity management is a process of focusing resources on the highest relative risks to public safety and monitoring the results. Feedback from regulators has been that many operators merely answer the questions asked by SHRIMP and accept SHRIMP’s risk ranking without applying their own knowledge of risks to their system. Likewise, many state auditors also do not fully understand the concept of risk management which does not fit into a “check the box” audit approach.
He used recent changes to SHRIMP to highlight other lessons learned. The addition of a subthreat for PermalockTM tapping tees demonstrates the importance of considering information from outside sources in an operator’s DIMP analysis. Issues with these tapping tees were included in an accident investigation conducted by the National Transportation Safety Board (NTSB). Other sources of outside information are the Pipeline and Hazardous Materials Safety Administration (PHMSA), industry conferences and meetings and participation in state, regional and national trade associations.
He closed by discussing the pending reauthorization of the pipeline safety act, which will undoubtedly impose new requirements for DIMP programs. In the aftermath of the fires and explosions in Massachusetts last September caused by an overpressure of a low pressure system, the final reauthorization bill is likely to include requirements that PHMSA amend the DIMP rule to include provisions to prevent such overpressure events.
For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at
jerickson@apga.org.