# AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG) — Notice of Amendment

- **operation:** document
- **citation:** CPF 520095017M
- **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:** 2009-03-17
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.120(a), 195.310(b)(9), 195.505(i), 195.573, 195.573(d), 195.573(e).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520095017M
**body:**

Notice of Amendment involving AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG). PHMSA's enforcement data identifies the cited regulations as 195.120(a),  195.310(b)(9),  195.505(i),  195.573,  195.573(d),  195.573(e). The case was opened on 2009-03-17 and is reported as closed as of 2009-04-28. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095017M_Notice of Amendment_03172009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095017M/520095017M_Notice%20of%20Amendment_03172009.pdf

520095017M_Notice of Amendment_03172009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095017M/520095017M_Notice%20of%20Amendment_03172009_text.pdf

520095017M_Operator Response_04152009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095017M/520095017M_Operator%20Response_04152009.pdf

520095017M_Notice of Amendment_03172009_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 17, 2009
Mr. Thomas Mushovic
General Manager
Aircraft Service International Group
6000 DeHavilland Drive
Anchorage, AK 99502-0246
CPF 5-2009-5017M
Dear Mr. Mushovic:
On February 2-5, 2009, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Aircraft
Services International Group’s (ASIG) Operation and Maintenance procedures and Operator
Qualification Plan in Anchorage, Alaska.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
ASIG’s plans or procedures, as described below:
1. §195.120(a) Passage of internal inspection devices.
Except as provided in paragraphs (b) and (c) of this section, each new pipeline and
each line section of a pipeline where the line pipe, valve, fitting or other line
component is replaced, must be designed and constructed to accommodate the
passage of instrumented internal inspection devices.
The operator must include a statement in the O & M Manual to ensure new construction
allows for pig passage.
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2. §195.310(b) (9) Records.
Where elevation differences in the section under test exceed 100 feet (30 meters), a
profile of the pipeline that shows the elevation and test sites over the entire length of
the test section.
The operator must include a statement in the O & M Manual to ensure that elevation
differences are accounted for during hydrotesting, when the elevation differences exceed
100 feet.
3. §195.573 What must I do to monitor external corrosion control?
(2) Identify not more than 2 years after cathodic protection is installed, the
circumstances in which a close-interval survey or comparable technology is
practicable and necessary to accomplish the objectives of paragraph 10.1.1.3 of
NACE Standard RP 0169.
The operator must determine and state in the O&M Manual the reinspection interval for
CIS readings.
4. §195.573 What must I do to monitor external corrosion control?
(d) Breakout tanks. You must inspect each cathodic protection system used to
control corrosion on the bottom of an aboveground breakout tank to ensure that
operation and maintenance of the system are in accordance with API Recommended
Practice 651. However, this inspection is not required if you note in the corrosion
control procedures established under Sec. 195.402(c)(3) why compliance with all or
certain operation and maintenance provisions of API Recommended Practice 651 is
not necessary for the safety of the tank.
The operator’s procedures references API 653, not API 651. The O&M Manual must be
changed to indicate that API 651 is the code to be followed for tank cathodic protection.
5. §195.573 What must I do to monitor external corrosion control?
(e) Corrective action. You must correct any identified deficiency in corrosion control
as required by Sec. 195.401(b). However, if the deficiency involves a pipeline in an
integrity management program under Sec. 195.452, you must correct the deficiency
as required by Sec. 195.452(h).
The operator’s procedures do not state how soon deficiencies in corrosion control would
be corrected. The O&M Manual must include a statement indicating the time to correct CP
deficiencies.
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6. §195.505 Qualification program.
(i) After December 16, 2004, notify the Administrator or a state agency participating
under 49 U.S.C. Chapter 601 if the operator significantly modifies the program after
the Administrator or state agency has verified that it complies with this section.
The operator’s plan must include a statement indicating that when the plan is significantly
modified, that PHMSA will be notified.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
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.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in
this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies
(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your
amended procedures to my office within 30 days of receipt of this Notice. This period may be
extended by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
In correspondence concerning this matter, please refer to CPF 5-2009-5017M and send all
responses to my attention at 222 W. 7th Ave. #200, Anchorage, Alaska 99513. For each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (#123892)
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