SIGNATURE FLIGHT SUPPORT, M&O _ HONOLULU — Notice of Probable Violation

party submissionOfficial PDF520075012_Operator Response_04052007.pdf#

5-2007-5012 asig nopv-pco 3-5-07_text.pdf, page 1Official PDFO U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 12300 W Dakota Ave, Suite 110 Lakewood, CO S0228 SENT TO COMPLIANCE REGISTRY Hardcopy Electrontcally ~ tt of Copies'/ Date ~o NOTICE OF PROBABLE VIOLATION and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT RE UESTED March 5, 2007 Mr. Joe Lovan Aircraft Service International Group 3201 Aolele Street Honolulu, HI 96819 CPF 5-2007-5012 Dear Mr. Lovan: On May 11, 2006, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Aircraft Service International Group (ASIG), Integrity Management Program (IMP) in Honolulu, HI. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation is: $195e452 Pipeline integrity management in high consequence areas (f) What are the elements of an integrity management program? An integrity management program begins with the initial framework. An operator must continually change the program to reflect operating experience, conclusions drawn from results of the integrity assessments, and other maintenance and surveillance data, and evaluation of consequences of a failure on the high consequence area. An operator must include, at minimum, each of the following elements in its written integrity management program: (3) An analysis that integrates all available information about the integrity of the entire pipeline and the consequences of a failure (see paragraph (g) of this section);#

5-2007-5012 asig nopv-pco 3-5-07_text.pdf, page 2Aircraft Service International Group did not complete an evaluation of risk on the facility, such as: valves and other appurtenances connected to line pipe, pumping units, fabricated assemblies associated with pumping units, metering and delivery stations and fabricated assemblies therein, and breakout tanks, Pro osed Com liance Order Pursuant to 49 United States Code ( 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Aircraft Service International Group. Please refer to the Proposed Compliance Order that is enclosed and made a part of this Notice, Res onse to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators rn Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. In your correspondence on this matter, please refer to CPF 5-2007-5012 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely Chris Hoi al Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 H. Nguyen (0117838)#

5-2007-5012 asig nopv-pco 3-5-07_text.pdf, page 3PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Aircraft Service International Group a Compliance Order incorporating the following remedial requirements to ensure the compliance of Aircraft Service International Group with the pipeline safety regulations: In regard to Item Number 1 of the Notice pertaining to your facilities. Aircraft Service International Group must perform an evaluation of risk on the facilities, Within 60 days of issuance of the Final Order, Aircraft Service International Group must complete the above items, and submit the required documentation and procedures to the Director, Western Region, Pipeline and Hazardous Materials Safety Administration, 12300 West Dakota Avenue, Suite 110, Lakewood, Colorado 8022S. Aircraft Service International Group shall maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. Costs shall be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and infrastructure.2) total cost associated with replacements, additions and other changes to pipeline#

520075012_Final Order_04222010_text.pdf, page 1Official PDFAPR 22 2010 Mr. Keith P. Ryan President Aircraft Service International Group 201 S. Orange Avenue, Suite 1100-A Orlando, FL 32801 Re: CPF No. 5-2007-5012 Dear Mr. Ryan: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation and finds that Aircraft Service International Group has completed the actions specified in the Notice to comply with the pipeline safety regulations. Therefore, this case is now closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Jeffrey D. Wiese Associate Administrator for Pipeline Safety Enclosure cc: Mr. Chris Hoidal, Director, Western Region, PHMSA Mr. Jason Maga Area General Manager of Maintenance & Operations Hawaii Fueling Facilities Corporation 3201 Aolele Street HFFC Airport Facility Honolulu, HI 96819 CERTIFIED MAIL – RETURN RECEIPT REQUESTED [7009 1410 0000 2472 5248]#

520075012_Final Order_04222010_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ______________________________ In the Matter of ) Aircraft Service International ) CPF No. 5-2007-5012 Group, ) ) ) ) Respondent. ) ______________________________) FINAL ORDER On May 11, 2006, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on- site pipeline safety inspection of the facilities and records of Aircraft Service International Group (ASIG or Respondent) in Honolulu, Hawaii. According to the OPS Violation Report, ASIG operates approximately 6 miles of regulated hazardous liquid pipelines that transport jet fuel in and around the Honolulu International Airport.1 As a result of the inspection, the Director, Western Region, OPS (Director), issued to Respondent, by letter dated March 5, 2007, a Notice of Probable Violation and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Respondent had violated 49 C.F.R. § 195.452(f)(3) and proposed ordering Respondent to take certain measures to correct the alleged violation. Respondent responded to the Notice by letter dated April 5, 2007 (Response). Respondent did not contest the allegations of violation and stated that it would comply with the terms of the proposed compliance order. Respondent did not request a hearing and therefore has waived its right to one. FINDING OF VIOLATION In its Response, ASIG did not contest the allegation in the Notice that it violated 49 C.F.R. Part 195, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(f)(3), which states: 1 “ASIG is a wholly owned subsidiary of BBA Aviation, a publicly held corporation traded on the London stock exchange providing Flight Support and Aftermarket Services and Systems to the commercial, business and general aviation, and military aviation markets.” http://www.asig.com/aboutus/ (accessed Apr. 20, 2010).#

520075012_Final Order_04222010_text.pdf, page 32 § 195.452 Pipeline integrity management in high consequence areas. (a) . . . (f) What are the elements of an integrity management program? An integrity management program begins with the initial framework. An operator must continually change the program to reflect operating experience, conclusions drawn from results of the integrity assessments, and other maintenance and surveillance data, and evaluation of consequences of a failure on the high consequence area. An operator must include, at minimum, each of the following elements in its written integrity management program: (1) . . . (3) An analysis that integrates all available information about the integrity of the entire pipeline and the consequences of a failure (see paragraph (g) of this section) . . . . The Notice alleged that ASIG did not perform an analysis that integrated all available information about the integrity of its entire pipeline, including valves and other appurtenances connected to line pipe, pumping units and associated fabricated assemblies, metering and delivery stations and associated fabricated assemblies, and breakout tanks, and the consequences of a failure as required by 49 C.F.R. § 195.452(f)(3). Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(f)(3) by failing to perform an analysis that integrates all available information about the integrity of its entire pipeline and the consequences of a failure. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 1 in the Notice for a violation of 49 C.F.R. § 194.452(f)(3). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. The Director has indicated that Respondent has taken the following actions specified in the proposed compliance order: During a March 24, 2009 Integrity Management Inspection of ASIG’s pipeline facilities, OPS confirmed that Respondent had satisfied the terms of the proposed compliance order.#

520075012_Final Order_04222010_text.pdf, page 43 Accordingly, I find that compliance has been achieved with respect to this violation. Therefore, the compliance terms proposed in the Notice are not included in this Order. The terms and conditions of this Final Order are effective upon receipt of service. ___________________________________ __________________________ Jeffrey D. Wiese Date Issued Associate Administrator for Pipeline Safety#