{"operation":"document","citation":"CPF 520095035W","title":"SIGNATURE FLIGHT SUPPORT, M&O _ HONOLULU — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-10-05","effective_on":null,"summary":"CLOSED warning letter citing 195.571, 195.573(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095035w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095035w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095035w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095035W","body":"Warning Letter involving SIGNATURE FLIGHT SUPPORT, M&O _ HONOLULU. PHMSA's enforcement data identifies the cited regulations as 195.571,  195.573(a)(1). The case was opened on 2009-10-05 and is reported as closed as of 2009-10-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520095035W_warning letter_10052009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095035W/520095035W_warning%20letter_10052009.pdf\n\n520095035W_warning letter_10052009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095035W/520095035W_warning%20letter_10052009_text.pdf\n\n520095035W_warning letter_10052009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 5, 2009\nJason Mega\nArea General Manager\nAirport Services International Group\n3201 Aolele Street\nHonolulu, HI 96819\nCPF 5-2009-5035W\nDear Mr. Mega:\nOn March 26, 2009, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected the Airport Services International\nGroup’s (ASIG) procedures and records of the tanks and pipelines at the Honolulu International Airport\nin Honolulu, Hawaii.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are:\n1. § 195.571 What criteria must I use to determine the adequacy of cathodic protection?\nCathodic protection required by this subpart must comply with one or more of the\napplicable criteria and other considerations for cathodic protection contained in\nparagraphs 6.2 and 6.3 of NACE Standard RP 0169 (incorporated by reference, see §\n195.3).\nASIG failed to provide adequate cathodic protection levels in accordance with NACE standard\nRP-0169, paragraphs 6.2 and 6.3, for the following breakout tanks and pipelines during the\nfollowing years:\n• Break tanks 1, 2, 3, 4, 5, 6, 7, 14, and 19 at the Sand island facility for the years 2006 and\n2007.\n• The 10” pipeline (6.0 mile) running from Sand Island to the Honolulu Airport in the years\n2006 and 2007.\n\n\n\nASIG’s annual cathodic protection reports dated November 2006 (Project number 07013.001)\nand March 2009 (Project number 1090118) shows that the cathodic protection levels do not meet\nthe NACE criteria.\n2. § 195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with Sec. 195.571:\n(1) Conduct tests on the protected pipeline at least once each calendar year, but with\nintervals not exceeding 15 months.\nASIG failed to provide records to show that they had conducted tests at least once a year, but with\nintervals not exceeding 15 months, to demonstrate that adequate cathodic protection levels are in\naccordance with NACE standard RP-0169, paragraphs 6.2 and 6.3 for the following breakout\ntanks and pipelines during the following years:\n• Break tanks 1, 2, 3, 4, 5, 15, 16, 17, 18, 19 at the Sand island facility for the years 2008 and\n2009.\n• The 10” pipeline (6.0 mile) running from Sand Island to the Honolulu Airport for the years\n2008 and 2009.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each\nviolation for each day the violation persists up to a maximum of $1,000,000 for any related series of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and\nhave decided not to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in ASIG being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 5-\n2009-5035W and send all responses to my attention at 222 W. 7th Ave. #200, PO Box 37, Anchorage\nAlaska 99513. Be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment 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 J. Strawn (#123948)\n2","truncated":false,"body_characters":4754}