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

- **operation:** document
- **citation:** CPF 520075012
- **title:** SIGNATURE FLIGHT SUPPORT, M&O _ HONOLULU — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-03-05
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.452(f)(3).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520075012
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520075012
**body:**

Notice of Probable Violation involving SIGNATURE FLIGHT SUPPORT, M&O _ HONOLULU. PHMSA's enforcement data identifies the cited regulation as 195.452(f)(3). The case was opened on 2007-03-05 and is reported as closed as of 2010-04-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

5-2007-5012 ASIG NOPV-PCO 3-5-07.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075012/5-2007-5012%20ASIG%20NOPV-PCO%203-5-07.pdf

5-2007-5012 asig nopv-pco 3-5-07_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075012/5-2007-5012%20asig%20nopv-pco%203-5-07_text.pdf

520075012_Final Order_04222010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075012/520075012_Final%20Order_04222010.pdf

520075012_Final Order_04222010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075012/520075012_Final%20Order_04222010_text.pdf

520075012_Operator Response_04052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075012/520075012_Operator%20Response_04052007.pdf

5-2007-5012 asig nopv-pco 3-5-07_text.pdf

O
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);



Aircraft 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)



PROPOSED 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

APR 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]



U.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).



2
§ 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.



3
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
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