{"operation":"document","citation":"CPF 520085010W","title":"AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-04-23","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(8), 195.452(h)(1), 195.452(h)(3), 195.452(h)(4)(i), 195.452(i)(1), 195.452(i)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085010W","body":"Warning Letter involving AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG). PHMSA's enforcement data identifies the cited regulations as 195.452(f)(8),  195.452(h)(1),  195.452(h)(3),  195.452(h)(4)(i),  195.452(i)(1),  195.452(i)(2). The case was opened on 2008-04-23 and is reported as closed as of 2008-04-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085010W_warning letter_04232008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085010W/520085010W_warning%20letter_04232008.pdf\n\n520085010w_warning letter_04232008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085010W/520085010w_warning%20letter_04232008_text.pdf\n\n520085010w_warning letter_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\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApril 23, 2008\nMr Thomas Mushovic\nGeneral Manager\nAircraft Service International Group\n6000 DeHavilland Drive\nAnchorage, AK 99519\nCPF 5-2008-5010W\nDear Mr. Mushovic.\nOn November 14-16, 2007, a representative of the Pipeline and Hazardous Materials Safety\nAdmmistration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Airport\nService International Group's (ASIG) Integrity Management Program m Anchorage, Alaska\nAs a result of the mspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations The items mspected and the\nprobable violations are:\n$195. 452 Pipeline integrity management in high consequence areas.\nf) 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\n\n\n\nintegrity management program:\n(8) A process for review of integrity assessment results and information analysis by\na person qualified to evaluate the results and information (see paragraph (h)(2) of\nthis section).\nASIG does not mclude m their IMP plan gob description, task analysis, or other means to\nidentify the qualification requirements for performing reviews of assessment results and\nmformation analysis, that address education, experience, skills, and trainmg\nrequirements, as appropriate.\n(Evidence i ASIG IM Program document, Section 2. 0\nf195. 452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(1) General requirements. An operator must take prompt action to address all\nanomalous conditions that the operator discovers through the integrity assessment\nor information analysis. In addressing all conditions, an operator must evaluate all\nanomalous conditions and remediate those that could reduce a pipeline's integrity.\nAn operator must be able to demonstrate that the remediation of the condition will\nensure that the condition is unlikely to pose a threat to the long-term integrity of\nthe pipeline. A reduction in operating pressure cannot exceed 365 days without an\noperator taking further remedial action to ensure the safety of the pipeline. An\noperator must comply with Sec. 195. 422 when making a repair.\nASIG does not mclude m their IM program document a requirement that any temporary\nreduction m operating pressure taken until repair or remediation can be completed\ncannot exceed 365 days without the operator takmg additional remedial actions to assure\nthe safety of the pipehne\n(Evidence i ASIG IM Program document, Section 2 5\n3. )195. 452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(3) Schedule for evaluation and remediation. An operator must complete\nremediation of a condition according to a schedule that prioritizes the conditions\nfor evaluation and remediation. If an operator cannot meet the schedule for any\ncondition, the operator must justify the reasons why it cannot meet the schedule\nand that the changed schedule will not jeopardize public safety or environmental\nprotection. An operator must notify OPS if the operator cannot meet the schedule\nand cannot provide safety through a temporary reduction in operating pressure.\nAn operator must send the notice to the address specified in paragraph (m) of this\nsec60n.\n\n\n\nASIG does not include in their IM program document a requirement to notify PHMSA if\nthe operator cannot meet the remediation schedule and cannot provide safety through a\ntemporary reduction in operating pressure.\n(Evidence) ASIG IM Program document, Section 2 5\n$195. 452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(4) Special requirements for scheduling remediation.\n(i) Immediate repair conditions. An operator's evaluation and remediation\nschedule must provide for immediate repair conditions. To maintain safety, an\noperator must temporarily reduce operating pressure or shut down the pipeline\nuntil the operator completes the repair of these conditions. An operator must\ncalculate the temporary reduction in operating pressure using the formula in\nsection 451. 7 of ASME/AIVSI B31. 4 (incorportaed by reference, see Sec. 195. 3). An\noperator must treat the following conditions as immediate repair conditions:\nASIG does not mclude m their IM program document a requirement statmg that if an\nimmediate repair condition is identified, the operating pressure of the affected pipehne\nbe temporarily reduced m accordance with the formula m Section 451. 7 of ASME/ANSI\nB31. 4 or the pipehne be shutdown until the condition is repaired. Where pressure\nreduction cannot be calculated using the method of Section 451 7, the process should\nidentify alternative methods of calculating a safe operatmg pressure\niiEvidence) ASIG IM Program document, Section 2 5\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\n(i) Terrain surrounding the pipeline segment, including drainage systems such as\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\n\n\n(viii) Exposure of the pipeline to operating pressure exceeding established\nmaximum operating pressure.\nASIG did not develop and document adequate risk assessment conclusions and\nimplementation actions ASIG appears to be domg the work but did not document what\nwork has been completed ASIG did not identify dominant risk factors nor mtegrate any\ndata with other information to develop a complete and mtegrated understanding of risk.\niiEvidence) ASIG IM Program document, Section 2. 4\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(1) General requirements. An operator must take measures to prevent and\nmitigate the consequences of a pipeline failure that could affect a high consequence\narea. These measures include conducting a risk analysis of the pipeline segment to\nidentify additional actions to enhance public safety or environmental protection.\nSuch actions may include, but are not limited to, implementing damage prevention\nbest practices, better monitoring of cathodic protection where corrosion is a\nconcern, establishing shorter inspection intervals, installing EFRDs on the pipeline\nsegment, modifying the systems that monitor pressure and detect leaks, providing\nadditional training to personnel on response procedures, conducting drills with\nlocal emergency responders and adopting other management controls.\nASIG does not mclude in their IM program document a requirement to consider the\nidentification of potential preventive and mitigative actions that address the most\nsignificant segment- specific risks, mcluding consideration of preventive and mitigative\nactions hsted m (195 452(i)(1) Further, ASIG did not conduct reviews of the\neffectiveness of current preventive and mitigative actions and the potential for\nenhancements and upgrades\nevidence) ASIG IM Program document, Section 2. 6\nUnder 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations We have reviewed the circumstances and supportmg documents\nmvolved m this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedmgs at this time We advise you to correct the items identified m this letter\nFailure to do so will result in ASIG bemg subject to additional enforcement action\nNo reply to this letter is required. If you choose to reply, m your correspondence please refer to\nCPF 5-2008-5010W Be advised that all material you submit in response to this enforcement\naction is subject to bemg made pubhcly available If you beheve that any portion of your\n\n\n\nresponsive material qualifies for confidential treatment under 5 U S C. 552(b), along with the\ncomplete origmal document you must provide a second copy of the document with the portions\nyou beheve quahfy for confidential treatment redacted and an explanation of why you beheve\nthe redacted information quahfies for confidential treatment under 5 U. S. C. 552(b).\nSmcerely,\nChris Hoidal\nDirector, Western Region\nPipelme and Hazardous Materials Safety Administration\ncc: PHP-60 Comphance Registry\nPHP-500 J Strawn (¹119912)","truncated":false,"body_characters":10359}