On November 6 and 7, John Erickson spoke on behalf of APGA and the APGA Security and Integrity Foundation (SIF) at the Kansas Public Service Commission’s Pipeline Safety Seminar in Manhattan, Kansas. In the SIF session, John focused on lessons learned after eight years of the SIF’s Simple Handy Risk-based Integrity Management Plan (SHRIMP) program. Over 1,600 distribution operators have used the SHRIMP program to develop their Distribution Integrity Management Plans (DIMP). 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.
On November 7, John represented APGA in a panel discussion on DIMP. Panelists discussed issues such as the regulation’s requirement that operators consider potential threats in their DIMP programs, especially the threat of vehicular damage to above ground facilities. Many Kansas utilities locate their meters at the property line rather than at the customer’s building and the Kansas Corporation Commission has noted that some operators have not included this threat in their DIMP. John discussed various utilities’ procedures for determining when meter sets require protection from vehicular damage.
For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at email@example.com