On October 9, John Erickson spoke on behalf of the APGA Security and Integrity Foundation (SIF) at the Michigan Public Service Commission’s annual seminar in Mount Pleasant, Mich. 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.
John 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.
John also gave a second presentation based on lessons learned from his experience testifying as an expert in many pipeline accident lawsuits. Among the issues that have been at issue are a utility’s responsibility to protect meter sets against vehicular damage and the placement of critical valves in distribution systems. In both instances he emphasized that operators having clear written procedures for meter protection and valve placement are best able to defend their policies against challenges.
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.