{"operation":"document","citation":"CPF 520095016W","title":"AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-03-17","effective_on":null,"summary":"CLOSED warning letter citing 195.577(a), 195.589(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095016W","body":"Warning Letter involving AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG). PHMSA's enforcement data identifies the cited regulations as 195.577(a),  195.589(b). The case was opened on 2009-03-17 and is reported as closed as of 2009-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520095016W_Warning Letter_03172009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095016W/520095016W_Warning%20Letter_03172009.pdf\n\n520095016W_Warning Letter_03172009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095016W/520095016W_Warning%20Letter_03172009_text.pdf\n\n520095016W_Warning Letter_03172009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 17, 2009\nMr. Thomas Mushovic\nGeneral Manager\nAircraft Service International Group\n6000 DeHavilland Drive\nAnchorage, AK 99502-0246\nCPF 5-2009-5016W\nDear Mr. Mushovic:\nOn February 2-5, 2009, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Aircraft\nServices International Group’s (ASIG) facilities and records in Anchorage, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §195.577(a) What must I do to alleviate interference currents?\n(a) For pipelines exposed to stray currents, you must have a program to identify,\ntest for, and minimize the detrimental effects of such currents.\nASIG contracted with Norton Corrosion Control (Norton) to conduct ASIG’s annual\nmonitoring of the Cross-Town Pipeline’s cathodic protection system. Norton conducted\nthe annual cathodic protection survey during August 4-8, 2008. Norton Corrosion\n\n\n\nControl provided the results of the August 2008 testing by a letter dated October 27,\n2008.\nFor the Nikiski Pipeline crossing (test station 20) the Norton report states that, “The\npotential on the Nikiski pipeline indicates the test wire is broken. The positive potential\nmay be due to interference, but there was minimal shift during the rectifier interruption,\nwhich would be more indicative of a broken wire”. Norton’s report indicates “on”\nstructure-to-soil potential on the Nikiski pipeline of + 224 mV relative to a permanent\ncopper-copper sulfate reference electrode (CSE) and – 30 mV relative to a portable\nCSE. An “instant off” structure-to-soil potential on the Nikiski pipeline is not presented\nin Norton’s report. Norton’s report does not include a recommendation relative to the\nNikiski Pipeline crossing.\nAs a result of initial questioning during the inspection, it appeared that the operator was\nunaware of the potential cathodic interference on the Nikiski Pipeline. The operator\nindicated that Norton will test the foreign line crossing during the 2009 annual cathodic\nprotection survey schedule for the summer of 2009.\nDue to the potential seriousness of cathodic interference, PHMSA believes that waiting\nuntil the 2009 summer testing season before additional investigations are conducted\nrelative to the potential cathodic interference on the Nikiski Pipeline, is not acting within\na reasonable time frame.\n2. §195.589 What corrosion control information do I have to maintain?\n(a) You must maintain current records or maps to show the location of--\n(1) Cathodically protected pipelines;\n(2) Cathodic protection facilities, including galvanic anodes, installed after\nJanuary 28, 2002; and\n(3) Neighboring structures bonded to cathodic protection systems.\n(b) Records or maps showing a stated number of anodes, installed in a stated\nmanner or spacing, need not show specific distances to each buried anode.\nASIG must maintain maps and records of cathodic protection facilities. The isolation\nflanges, test stations, rectifier locations and galvanic anodes were not represented on the\ndrawings.\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 supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result in ASIG being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2009-5016W and send all responses to my attention at 222 W. 7th Ave. #200,\nAnchorage, Alaska 99513. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders (#123892)\n3","truncated":false,"body_characters":5441}