{"operation":"document","citation":"CPF 520085009M","title":"AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-04-23","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(7), 195.452(i)(2), 195.452(i)(3), 195.452(i)(4), 195.452(j)(2), 195.452(j)(4)(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085009M","body":"Notice of Amendment involving AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG). PHMSA's enforcement data identifies the cited regulations as 195.452(f)(7),  195.452(i)(2),  195.452(i)(3),  195.452(i)(4),  195.452(j)(2),  195.452(j)(4)(i). The case was opened on 2008-04-23 and is reported as closed as of 2008-08-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085009M_notice of amendment_04232008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085009M/520085009M_notice%20of%20amendment_04232008.pdf\n\n520085009m_notice of amendment_04232008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085009M/520085009m_notice%20of%20amendment_04232008_text.pdf\n\n520085009M_operator response_05202008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085009M/520085009M_operator%20response_05202008.pdf\n\n520085009m_notice of amendment_04232008_text.pdf\n\nO\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApril 23, 2008\nMr. Thomas Mushovic\nGeneral Manager\nAircraft Services International Group (ASIG)\n6000 DeHavilland Drive\nAnchorage, AK 99519\nCPF 5-2008-5009M\nDear Mr Mushovic\nBetween November 11-14, 2007, a representative of the Pipehne and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, mspected\nASIG's records and procedures for its Integrity Management program m Anchorage, Alaska.\nOn the basis of the mspection, PHMSA has identified apparent inadequacies found within\nASIGs' plans or procedures, as described below.\nPreventative and Mitigative Measures\n$195. 452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(2) Risk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the likelihood of a pipeline release\noccurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited to:\n(i) Terrain surrounding the pipeline segment, including drainage systems such as\n\n\n\nsmall streams and other smaller waterways that could act as a conduit to the high\nconsequence area;\n(ii) Elevation profile;\n(iii) Characteristics of the product transported;\n(iv) Amount of product that could be released;\n(v) Possibility of a spillage in a farm field following the drain tile into a waterway;\n(vi) Ditches along side a roadway the pipeline crosses;\n(vii) Physical support of the pipeline segment such as by a cable suspension bridge;\n(viii) Exposure of the pipeline to operating pressure exceeding established\nmaximum operating pressure.\n~ Item 1A: )194 452 (i)(2)\nASIG did not have adequate procedures that considers the items m )195 452 (i) (2)\nASIG must consider all risk factors, mcludmg, but not hmited to.\n(i) Terram surroundmg the pipehne segment, mcluding drainage systems such as small\nstreams and other smaller waterways that could act as a conduit to the high consequence\narea, (n) Elevation profile, (ni) Characteristics of the product transported, (iv) Amount\nof product that could be released, (v) Possibihty of a spillage m a farm field followmg\nthe drain tile mto a waterway; (vi) Ditches along side a roadway the pipehne crosses,\n(vii) Physical support of the pipehne segment such as by a cable suspension bridge, (viii)\nExposure of the pipehne to operatmg pressure exceeding estabhshed maximum\noperatmg pressure\nPreventative and Mitigative Measures\n$195. 452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n3) Leak detection. An operator must have a means to detect leaks on its pipeline\nsystem. An operator must evaluate the capability of its leak detection means and\nmodify, as necessary, to protect the high consequence area. An operator's\nevaluation must, at least, consider, the following factors — length and size of the\npipeline, type of product carried, the pipeline's proximity to the high consequence\narea, the swiftness of leak detection, location of nearest response personnel, leak\nhistory, and risk assessment results.\n~ Item 1A: )194. 452 (i)(3)\nASIG did not have adequate procedures to take mto account the factors outlmed m\n(195 452(1)(3) ASIG did not conduct a formal analysis to assess the capabihty of its\nleak detection means and modify, as necessary, to protect the high consequence area\nAn operator's evaluation must, at least, consider the followmg factors-length and size of\nthe pipehne, type of product carried, the pipehne's proximity to high consequence area,\nthe saltiness ot Leak d, elect~on, locabm, oft eMest response pcrsonneY, leak r. story, +~6\nrisk assessment resuhs.\n\n\n\nPreventative and Mitigative Measures\n$195. 452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an\nEFRD is needed on a pipeline segment to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, an operator must install the EFRD. In\nmaking this determination, an operator must, at least, consider the following\nfactors — the swiftness of leak detection and pipeline shutdown capabilities, the type\nof commodity carried, the rate of potential leakage, the volume that can be\nreleased, topography or pipeline profile, the potential for ignition, proximity to\npower sources, location of nearest response personnel, specific terrain between the\npipeline segment and the high consequence area, and benefits expected by reducing\nthe spill size.\n~ Item 1A: )194. 452 (i)(4)\nASIG procedures did not consider all of the factors outhned m 452 (i) (4) ASIG did not\ncomplete an evaluation of the need for additional EFRDs to respond to releases during\ntransient conditions. ASIG did not consider the potential effects of additional EFRDs,\nmcluding a) conductmg proper valve sequencmg during mtended EFRD activations, b)\nthe operator's ability to promptly detect and react to madvertent EFRD activations, and\nc) possible elevated pressures caused by transient conditions during EFRD activations\nPreventative and Mitigative Measures\n$195. 452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(2) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure pipeline integrity. An operator must base the frequency of\nevaluation on risk factors specific to its pipeline, including the factors specified in\nparagraph (e) of this section. The evaluation must consider the results of the\nbaseline and periodic integrity assessments, information analysis (paragraph (g) of\nthis section), and decisions about remediation, and preventive and mitigative\nactions (paragraphs (h) and (i) of this section).\n~ Item 1A: )194. 452 (l)(2)\nASIG did not have adequate procedures to identify contmual processes and procedures\nthat meet the requirements of )195 452 (l) (2). All relevant mformation was not\nadequately considered and adequate justifications were not developed for reassessment\nmtervals\n\n\n\n5. Preventative and Mitigative Measures\n$195. 452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(4) Variance from the 5-year intervals in limited situations-\n(i) Engineering basis. An operator may be able to justify an engineering basis for a\nlonger assessment interval on a segment of line pipe. The justification must be\nsupported by a reliable engineering evaluation combined with the use of other\ntechnology, such as external monitoring technology, that provides an\nunderstanding of the condition of the line pipe equivalent to that which can be\nobtained from the assessment methods allowed in paragraph (j)(5) of this section.\nAn operator must notify OPS 270 days before the end of the five-year (or less)\ninterval of the justification for a longer interval, and propose an alternative\ninterval. An operator must send the notice to the address specified in paragraph\n(m) of this section.\n(ii) Unavailable technology. An operator may require a longer assessment period\nfor a segment of line pipe (for example, because sophisticated internal inspection\ntechnology is not available). An operator must justify the reasons why it cannot\ncomply with the required assessment period and must also demonstrate the actions\nit is taking to evaluate the integrity of the pipeline segment in the interim. An\noperator must notify OPS 180 days before the end of the five-year (or less) interval\nthat the operator may require a longer assessment interval, and provide an\nestimate of when the assessment can be completed. An operator must send a notice\nto the address specified in paragraph (m) of this section.\n~ Item 1A: (194. 452 (l)(4)\nASIG does not have adequate procedures in their IM Program to include provisions for\nsubmitting variance notifications to PHMSA for assessment mtervals longer than the 5-\nyear maximum assessment interval~\nProgram Evaluation\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection);\n~ Item 1A: )194. 452 (f)(7)\n\n\n\nASIG does not have adequate procedures to demonstrate that they have an effective root\ncause analysis and a lessons learned program.\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U S. C ) 60108(a) and 49 C F R. ( 190 237 Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subJect to being\nmade pubhcly available If you beheve that any portion of your responsive material quahfies\nfor confidential treatment under 5 U S. C 552(b), along with the complete origmal document\nyou must provide a second copy of the document with the portions you believe quahfy for\nconfidential treatment redacted and an explanation of why you beheve the redacted mformation\nquahfies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations m this\nNotice and authorizes the Associate Admmistrator for Pipelme Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Fmal Order\nIf, after opportumty for a hearing, your plans or procedures are found madequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C F. R. ) 190. 237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office withm 30 days of receipt of this Notice This period may be\nextended by written request for good cause Once the madequacies identified herem have been\naddressed m your amended procedures, this enforcement action will be closed\nIn correspondence concerning this matter, please refer to CPF 5-2008-5009M and, for each\ndocument you submit, please provide a copy m electronic format whenever possible\nSmcerely,\nChris Hoidal\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\ncc PHP-60 Comphance Registry\nPHP-500 J Strawn (4119912)\nEnclosure Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":12294}