SIGNATURE FLIGHT SUPPORT, M&O _ HONOLULU — Safety Order

party submissionOfficial PDF520156002S_Operator Response to Notice and Request for Consultation Meeting_08212015.pdf#

520156002S_Closure letter_11222017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED November 22, 2017 Mr. Jason Maga General Manager Signature Flight Support Honolulu International Airport 3201 Aolele Street Honolulu, HI 96819 CPF 5-2015-6002S Closure Letter Dear Mr. Maga: On May 25, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Aircraft Service International Group (ASIG) a Consent Order in the above- referenced case. This Order incorporated the terms of a Consent Agreement, with requirements to take certain corrective measures to remedy the alleged conditions at the Sand Island Tank Facility in Oahu, Hawaii. Based on our review of the documentation you provided, it has been determined that you have complied with all of the terms of the Consent Agreement and Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Kim West Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 R. Reineke#

520156002S_Notice of Proposed Safety Order_06222015_text.pdf, page 1Official PDFTRANSMITTED VIA EMAIL & CERTIFIED MAIL - RETURN RECEIPT REQUESTED June 22, 2015 Mr. Lawrence McMahon Vice-President, Fuel Consortiums Aircraft Services International Group (ASIG) ASIG/LAX Fuel 9900 LAXfuel Road Los Angeles, CA 90045 CPF 5-2015-6002S Sand Island Tank Facility Dear Mr. McMahon: Enclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The Notice proposes that Aircraft Services International Group (ASIG) take certain measures with respect to the Hawaii Fueling Facilities Corporation’s Sand Island Tank Facility in Honolulu, Hawaii. Your options for responding are set forth in the Notice. Your receipt of the Notice constitutes service of that document under 49 C.F.R. §190.5. We look forward to a successful resolution to ensure pipeline safety. Please direct any questions on this matter to me at 720-963-3160. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: cc: Notice of Proposed Safety Order Copy of 49 C.F.R. § 190.239 Mr. Jason Maga, Assistant Treasurer, ASIG#

520156002S_Notice of Proposed Safety Order_06222015_text.pdf, page 2DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY ____________________________________ In the Matter of ) Aircraft Services International Group, ) CPF No. 5-2015-6002S ) ) ) Respondent ) ____________________________________) NOTICE OF PROPOSED SAFETY ORDER Background and Purpose Pursuant to Chapter 601 of title 49, United States Code, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has initiated an investigation of the safe operation of the Sand Island Tank Facility in Oahu, Hawaii. This tank facility is owned by Hawaii Fueling Facilities Corporation (HFFC) and operated by the Aircraft Services International Group (ASIG). The Sand Island Tank Facility receives jet fuel from PHMSA-regulated pipelines operated by other companies. ASIG stores the jet fuel in PHMSA-regulated “breakout tanks” prior to being transported by their pipelines to the Honolulu International Airport. The investigation was prompted after PHMSA was notified on January 21, 2015 by the National Response Center of a jet fuel release from Tank 2 at the Sand Island Tank Facility. As a result of the investigation, it appears conditions exist at this breakout tank facility posing an integrity risk to public safety, property, or the environment. Pursuant to 49 U.S.C. § 60117(l), PHMSA issues this Notice, notifying you of the preliminary findings of the investigation, and proposing that you take measures to ensure that the public, property, and the environment are protected from the potential risk. Preliminary Findings • The affected breakout tank facility is known as the Sand Island Tank Facility (Tank Facility). The Tank Facility receives, stores, and delivers jet fuel for airplanes serviced at the Honolulu International Airport. The Tanks Facility consists of 16 above ground storage tanks that receive and supply fuel via both PHMSA and US Coast Guard regulated pipelines which defines the tanks at the Tank Facility as PHMSA-regulated breakout tanks subject to 49 CFR Part 195 regulations. The definition of a breakout tank is specified in §195.2.#

520156002S_Notice of Proposed Safety Order_06222015_text.pdf, page 3• Tank 2 of the Tank Facility was constructed in 1973, with a new single-bottom floor installed in 1989. The 15 other tanks on the Tank Facility were constructed between 1966 and 1989, and each can store between 25,000 barrels and 132,000 barrels of jet fuel. • The Tank Facility is located adjacent to the Honolulu Harbor. The Tank Facility is situated within an ecological Unusually Sensitive Area, as defined in 49 CFR 195.6, and a densely populated industrial area near downtown Honolulu. • In December 2014, ASIG controllers noted inventory discrepancies after filling Tank 2 via ocean vessel. As a result, ASIG emptied, degassed, and cleaned Tank 2 beginning on December 26, 2014. The floor was scanned by Magnetic Flux Leakage (MFL) tool and metal loss was noted at a 6-inch repair patch of the floor near the tank’s center sump. ASIG stated the leak was caused by a failure of the weld at this patch location. • At approximately 7:02 pm HST on January 21, 2015, PHMSA was notified by the National Response Center (NRC #1106276) of a leak at Tank 2 of the Tank Facility (Accident). An estimated 42,000 gallons of jet fuel seeped from Tank 2. • The last inspection per API Standard 653 Tank Inspection, Repair, Alteration and Reconstruction (API 653 Out-of Service Inspection) on Tank 2 was performed in September 2007. The next API 653 Out-of Service Inspection was scheduled for 2017. An annual internal inspection and cleaning (Annual Cleaning Inspection) of Tank 2 was performed in August 2014, with no issues found on the tank floor. • On March 11, 2015, PHMSA inspectors initiated an investigation of the Tank 2 Accident. This investigation identified numerous safety and regulatory issues relating to the inspection, record keeping, ongoing floor corrosion, and previous floor repairs of Tank 2. Specifically, the previous two API 653 Out-of-Service Inspections (in 2000 and 2007) on Tank 2 did not: o Identify that undersized patches were used to repair the tank floor. o Identify all tank patch locations in the tank floor, including several that had been installed between 1998 and the present. o Identify that some of the patches were placed over lap welds between floor plates. o Identify several recommendations made in a 1996 inspection report that were not performed at that time because the tank had already been placed back in service, including:  Lap welds stepped in the wrong direction,  Undersized fillet welds,  Lack of an API required hydrotest after the floor to shell fillet weld was repaired, and  Use of both full penetration butt welds and lap welds on the annular ring. o Use the proper data to determine the remaining life of the tank floor and the time until the next scheduled API 653 Out-of-Service Inspection. The 2000 API 653 Out-of-Service Inspection report indicates pits in the annular ring of the tank but the 2007 report does not indicate any pits. Furthermore, the operator had no records of a floor repair between 2000 and 2007 and did not recall any floor repairs taking place during this period. o Include the bottom thickness UT readings in the 2007 report.#

520156002S_Notice of Proposed Safety Order_06222015_text.pdf, page 4o Identify tank floor issues that required repair. No issues were indicated with the tank floor in the 2007 inspection report, API 653 Appendix C, checklist despite the fact that many issues existed. • ASIG did not conduct an API 653 Out-of-Service Inspection within the timeframe recommended by the last API 653 report. The time until the next inspection is listed as 5.33 years in the 2007 report; however, the tank did not have another API 653 Out-of- Service Inspection performed on it prior to its failure in December 2014. • There were deficiencies in ASIG’s records regarding Tank 2: o The operator believed that the tank had a double floor when there was only a single floor. o No construction drawing records exist. o The operator believed that there was a sand layer installed beneath the tank floor when it is actually it appears to be a coarse material as observed by the PHMSA inspector at that time. o A 1998 inspection report documents several patches installed on the floor, but subsequent inspection reports do not indicate any patches. Inspection of the tank floor in March 2015 identified several more patches installed that were not indicated on the 1998 drawing, but the operator had no record of them ever being installed. No records exist of the additional patches installed between 1998 and the present. o The Tank 2 maintenance records and inspection reports do not properly document floor repairs. • The authorized tank inspector (AI), “Inspector A” who last inspected Tank 2 also performed API 653 Out-of-Service Inspection on other tanks at the Tank Facility. The quality level of previous API 653 Out-of-Service Inspection including record keeping and analysis of results of the other 15 storage tanks at this facility is therefore questionable. Based on the information provided by ASIG, Inspector A performed the last API 653 Out- of-Service Inspection on the following tanks: 3, 4, 5, 6, 11, 12, 13, 15, 16, 17, and 18. A different inspector, “inspector B”, performed the last API 653 Out-of-Service Inspection on the four other tanks but inspector A had also performed API 653 Out-of-Service Inspections on these tanks in the past. Based on inspector A’s involvement in inspecting all of the other 15 tanks in the past and ASIG’s poor recordkeeping of the tanks, we have concerns about the integrity of all 15 other tanks. ASIG has indicated that they have concerns about many, but not all, of the tanks as well and has begun the process of performing API 653 Out-of-Service Inspections on the tanks that they are most concerned about. Proposed Issuance of Safety Order Section 60117(l) of Title 49, United States Code, provides for the issuance of a safety order, after reasonable notice and the opportunity for a hearing, requiring corrective measures, which may include physical inspection, testing, repair, or other action, as appropriate. The basis for making#

520156002S_Notice of Proposed Safety Order_06222015_text.pdf, page 5the determination that a pipeline facility has a condition or conditions that pose a pipeline integrity risk to public safety, property, or the environment is set forth both in the above- referenced statute and 49 C.F.R. § 190.239, a copy of which is enclosed. After evaluating the foregoing preliminary findings of fact and considering the deficiencies in the inspection, record keeping, floor corrosion, and floor repairs of Tank 2, the concern regarding the quality and competence of the inspections of the other 15 tanks in the Tank Facility, the age of the tanks involved, the hazardous nature of the product transported, the characteristics of the geographical areas where the pipeline facility is located, and the likelihood that the conditions could worsen or develop on other areas of the facility and potentially impact its serviceability, it appears that the continued operation of the affected pipeline facility without corrective measures would pose a pipeline integrity risk to public safety, property, or the environment. Accordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the proposed issuance of a safety order and to propose that Respondent take measures specified herein to address the potential risk. Response to this Notice In accordance with § 190.239, you have 30 days following receipt of this Notice to submit a written response to the official who issued the Notice. If you do not respond within 30 days, this constitutes a waiver of your right to contest 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 Safety Order. In your response, you may notify that official that you intend to comply with the terms of the Notice as proposed, or you may request that an informal consultation be scheduled. Informal consultation provides you with the opportunity to explain the circumstances associated with the risk conditions alleged in the notice and, as appropriate, to present a proposal for a work plan or other remedial measures, without prejudice to your position in any subsequent hearing. If you and PHMSA agree within 30 days of informal consultation on a plan and schedule for you to address each identified risk condition, we may enter into a written consent agreement (PHMSA would then issue an administrative consent order incorporating the terms of the agreement). If a consent agreement is not reached, or if you have elected not to request informal consultation, you may request an administrative hearing in writing within 30 days following receipt of the Notice or within 10 days following the conclusion of an informal consultation that did not result in a consent agreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to have a condition that poses a pipeline integrity risk to the public, property, or the environment in accordance with § 190.239, the Associate Administrator may issue a safety order. 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).#

520156002S_Notice of Proposed Safety Order_06222015_text.pdf, page 6In your correspondence on this matter, please refer to CPF 5-2015-6002S and for each document you submit, please provide a copy in electronic format whenever possible. Proposed Corrective Measures Pursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, PHMSA proposes to issue a safety order to ASIG incorporating the following requirements with respect to the Tank Facility: 1. 2. 3. 4. 5. 6. 7. 8. Within 30 days of receiving this Safety Order, develop and submit to the Director a Work Plan for performing an API 653 Out-of-Service Tank Inspection on each tank at the Tank Facility that has not received an API 653 Out-of-Service Tank inspection since December 2014. The Work Plan must utilize a risk based prioritization methodology, include a schedule, and must provide for all inspections and repairs to be complete by December 31, 2016. The Work Plan will be incorporated into the Safety Order. Within 30 days of receiving this Safety Order, for any tank that has had an API 653 Out- of-Service Inspection performed since December 2014, submit the date of the inspection, and supporting inspection and repair documentation to the Director. For API 653 Out of Service Inspections done before December 2014, the Director may consider exemption from the Work Plan based on an explanation and supporting documentation of the accuracy of the last API 653 Out-of-Service Inspection. Once approved by the Director, implement the Work Plan according to the schedule set forth in it. Submit any changes to the Work Plan to the Director for approval prior to implementing the changes. Within 30 days of receiving this Safety Order , submit the name, address and contact information of a third party inspector to be used to review the results of all API 653 Out- of-Service Tank Inspections performed as a result of this Safety Order for approval by the Director. Once approved by the Director, utilize the services of the third-party inspector to review the records and results of each API 653 Out-of-Service Tank Inspection performed as a result of this Safety Order. Submit a report with the results of this review to the Director prior to placing the tank back into service. Perform all necessary mandatory repairs required by the API 653 Out-of-Service Tank Inspections and submit evidence to the Director that each repair was completed properly prior to placing each tank back into service. Perform all necessary non-mandatory repairs required by the API 653 Out-of-Service Tank Inspections and submit evidence to the Director that each repair was completed properly prior to placing each tank back into service. In lieu of performing the non- mandatory repairs, submit an explanation as to why the non-mandatory repairs do not need to be completed prior to placing the tank back into service to the Director for approval prior to placing the tank back into service. The Director will make a#

520156002S_Notice of Proposed Safety Order_06222015_text.pdf, page 7determination as to whether or not the non-mandatory repairs must be completed prior to placing the tank back into service. 9. Submit monthly reports to the Director that: (1) include available data and results of the inspections required by the Safety Order; (2) describe the progress of the repairs and other remedial actions being undertaken; and (3) provide tank inventory data to demonstrate that the tanks are not leaking. The reports must be submitted on the 1st of each month beginning on July 1, 2015. 10. The Director may grant an extension of time for compliance with any of the terms of the Safety Order upon a written request submitted in a timely manner demonstrating good cause for an extension. 11. Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator shall be final. 12. It is requested (not mandated) that ASIG maintain documentation of the safety improvement costs associated with fulfilling this Safety Order and submit the total to the Director. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure will be made. The actions proposed by this Notice of Proposed Safety Order are in addition to and do not waive any requirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other provision of Federal or state law. After receiving and analyzing additional data in the course of this proceeding and implementation of the work plan, PHMSA may identify other safety measures that need to be taken. In that event, Respondent will be notified of any proposed additional measures and, if necessary, amendments to the Work Plan or Safety Order will be made. ___________________________________ __________________ Chris Hoidal Date issued Director, Western Region Pipeline and Hazardous Materials Safety Administration#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 1Official PDFMay 25, 2016 Mr. Tony Lefebvre President and Chief Operating Officer Aircraft Service International Group, Inc. 201 S. Orange Avenue, Suite 1100-A Orlando, Florida 32801 Re: CPF No. 5-2015-6002S Dear Mr. Lefebvre: Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between Pipeline and Hazardous Materials Safety Administration (PHMSA) and Aircraft Services International Group (ASIG) which was executed on April 26, 2016. Service of the Consent Order and Consent Agreement by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Acting Associate Administrator for Pipeline Safety Enclosure cc: Mr. Chris Hoidal, Director, Western Region, Office of Pipeline Safety, PHMSA Mr. Lawrence McMahon, Vice President, Fuel Consortiums, ASIG/LAX Fuel, 9900 LAXfuel Road, Los Angeles, California 90045 CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ) In the Matter of ) ) Aircraft Service International Group, Inc., ) CPF No. 5-2015-6002S ) Respondent. ) ) CONSENT ORDER By letter dated June 22, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, issued a Notice of Proposed Safety Order (Notice) to Aircraft Service International Group, Inc. (ASIG), a subsidiary of BBA Aviation plc,1 and which operates the Sand Island Tank Facility in Oahu, Hawaii (Tank Facility). The Tank Facility receives jet fuel in PHMSA-regulated breakout tanks prior to being transported by ASIG pipelines to the Honolulu International Airport. In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions existed at the Tank Facility that posed an integrity risk to public safety, property, or the environment. The Notice also proposed that ASIG take certain corrective measures to remedy the alleged conditions and ensure that the public, property, and the environment were protected from the potential risk. In response to the Notice, Respondent requested an informal consultation, whereupon the parties engaged in good-faith settlement discussions that resulted in the Consent Agreement attached to this Order and that settles all of the allegations in the Notice. Accordingly, the foregoing Consent Agreement is hereby approved and incorporated by reference into this Order. The Respondent is hereby ordered to comply with the terms of the Consent Agreement, effective immediately. Pursuant to 49 U.S.C. 60101, et seq., failure to comply with this Consent Order may result in the assessment of civil penalties of up to $200,000 per violation per day, or in the referral of the case for judicial enforcement. 1 http://www.bbaaviation.com/about-us/company-overview/company-structure.aspx (last viewed May 22, 2016).#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 3CPF No. 5-2015-6002S Page 2 The terms and conditions of this Consent Order are effective upon service in accordance with 49 C.F.R. § 190.5. __________________________________ _________________________ Alan K. Mayberry Date Issued Acting Associate Administrator for Pipeline Safety#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 4U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ) In the Matter of ) ) Aircraft Services International Group, ) CPF No. 5-2015-6002S ) Respondent. ) ) CONSENT AGREEMENT On June 22, 2015, the Regional Director for the Western Region (the Region) of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS or the Agency), issued a Notice of Proposed Safety Order (Notice) to Aircraft Services International Group (ASIG), which operates the Sand Island Tank Facility in Oahu, Hawaii (Tank Facility), owned by the Hawaii Fueling Facilities Corporation (HFFC). The Notice alleged that conditions exist at the Tank Facility that might pose an integrity risk to public safety, property, or the environment. The Notice also proposed that ASIG take certain corrective measures to remedy the alleged conditions at the Tank Facility and ensure that the public, property, and the environment were protected from the potential risk. ASIG responded to the Notice by timely submitting a written response, including a proposed work plan, and request for an informal consultation. An informal consultation was held on November 18, 2015. During the informal consultation, the PHMSA and ASIG agreed that settlement of this proceeding will avoid further administrative proceedings or litigation of this Notice and that entry into this Consent Agreement is the most appropriate means of resolving issues raised in the Notice and in the public interest. Therefore, pursuant to 49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and agreement of Respondent and the PHMSA (the Parties), the Parties agree as follows: I. General Provisions 1. Respondent acknowledges that as the operator of the Tank Facility, Respondent and its tank facility system are subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101 et seq. and the regulations and administrative orders issued thereunder. For purposes of this Consent Agreement, Respondent acknowledges that it received proper notice of the PHMSA’s action in this proceeding and that the Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101 et seq. and the regulations and orders issued thereunder.#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 52. Respondent agrees, for purposes of this Consent Agreement, to address the integrity risks identified in the Notice by completing the actions specified in Part III of this agreement (Corrective Measures) and to abide by the terms of this Consent Agreement. This Consent Agreement does not constitute a finding of violation of any Federal law or regulation and may not be used in any civil or administrative proceeding of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this Consent Agreement. 3. After Respondent returns this signed agreement, the PHMSA’s representative will present it to the Associate Administrator for Pipeline Safety recommending that the Associate Administrator adopt the terms of this agreement by issuing an administrative order (Consent Order) incorporating the terms of this Consent Agreement. The terms of this agreement constitute an offer of settlement until accepted by the Associate Administrator. Once accepted, the Associate Administrator will issue a Consent Order incorporating the terms of the agreement. 4. Respondent consents to the issuance of the Consent Order, and hereby waives any further procedural requirements with respect to its issuance. Respondent waives all the rights to contest the adequacy of notice, or the validity of the Consent Order, including all rights to administrative or judicial hearings or appeals, except as set forth herein. 5. This Consent Agreement shall apply to and be binding upon the PHMSA, and upon Respondent, its officers, directors and employees, and its successors, assigns, or other entities or persons otherwise bound by law. Respondent agrees to provide a copy of this Consent Agreement and any incorporated work plans and schedules to all of Respondent’s officers, employees, and agents whose duties might reasonably include compliance with this Consent Agreement. 6. For all transfers of operating responsibility of the Tank Facility, Respondent shall provide a copy of this Consent Agreement to the prospective transferee at least 30 days prior to such transfer and simultaneously provide written notice of the prospective transfer to the PHMSA Region Director (Director) who issued the Notice. 7. This Consent Agreement constitutes the final, complete and exclusive agreement and understanding between the Parties with respect to the settlement embodied in this Consent Agreement, and resolves any claims that have been or could have been alleged regarding (1) the PHMSA investigation of the Tank Facility that was conducted on March 11, 2015, in connection with the January 21, 2015 leak at Tank 2 of the Tank Facility that resulted in an estimated 42,000 gallons of jet fuel seeping from Tank 2 and (2) a records review by PHMSA investigators concerning the integrity of the other 15 tanks at the Tank Facility, which are included in this Consent Agreement. The Parties acknowledge that there are no representations, agreements, or understandings relating to the settlement other than those expressly contained in this Consent Agreement, except that the terms of this Consent Agreement may be construed by reference to the Notice. CPF 5-2015-6002S will be closed once ASIG submits its Final Report to the Director. 8. Nothing in this Consent Agreement affects or relieves Respondent of its responsibility to comply with all applicable requirements of the Federal pipeline safety laws, 49 2#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 6U.S.C. § 60101 et seq., and the regulations and orders issued thereunder. Nothing in this Consent Agreement alters the PHMSA’s right of access, entry, inspection, and information gathering or the PHMSA’s authority to bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the regulations and orders issued thereunder, or any other provision of Federal or State law. 9. This Consent Agreement does not waive or modify any Federal, State, or local laws or regulations that are applicable to Respondent’s pipeline systems. This Consent Agreement is not a permit, or a modification of any permit, under any Federal, State, local laws or regulations. Respondent remains responsible for achieving and maintaining compliance with all applicable Federal, State, and local laws, regulations and permits. 10. This Consent Agreement does not create rights in, or grant any cause of action to, any third party not party to this Agreement. The U.S. Department of Transportation is not liable for any injuries or damages to persons or property arising from acts or omissions of Respondent or its officers, employees, or agents carrying out the work required by this Consent Agreement. Respondent agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents and representatives from any and all causes of action arising from any acts or omissions of Respondent or its contractors in carrying out any work required by this Consent Agreement. I. Completed Corrective Measures 11. In response to the Safety-Related Condition described in the Notice, to date, ASIG has completed the following corrective measures: (A) ASIG has selected and the Director has approved an independent third party inspector, Engineering and Inspections Hawaii, Inc., to review the records and results of all API 651, 652, and 653 Inspections performed under this Consent Agreement. (B) ASIG has completed API 653 Out-of-Service Tank Inspections for Tanks 1 and 4. The results of those inspections were reviewed by Engineering and Inspections Hawaii, Inc. Repairs to those tanks were performed and they have been approved for continued service. (C) ASIG has completed API 653 Out-of-Service Tank Inspections for Tanks 2 and 7. The results of those inspections were reviewed by Engineering and Inspections Hawaii, Inc. These tanks require repair before they can be returned to service. III. Corrective Measures 12. Upon issuance of the Consent Order, Respondent agrees to perform the additional Corrective Measures set forth below. 13. In regard to Tank Nos. 6, 11 and 12, in which a second liner, cathodic protection system and tank floor were installed in 2014, and Tank No. 13, in which the tank floor was 3#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 7removed and a liner, cathodic protection system and tank floor were installed in 2013, ASIG must hire a third-party inspector to conduct an independent review of the extensive work done on these tanks to confirm compliance with API 651, 652, and 653. This must be completed by no later than March 31, 2017, contingent on the extent of repairs required on each of the tanks in item 14. .If a tank is taken out of service for an inspection, PHMSA agrees that an extension will be granted to allow Respondent to delay inspection for the next tank to be inspected, until the preceding tank is back in service. The intent of this extension is to prevent more than one tank at a time being taken out of service. 14. ASIG must perform API 653 Out-of-Service Inspections on Tank Nos. 3, 5, 14, 15, 16, 17, 18, and 19, and hire a third-party inspector to conduct an independent review of the results of these inspections. ASIG must perform all repairs that are critical to the integrity of the tank and submit evidence to the Director that each repair was completed properly prior to placing each tank back into service. This must be completed by no later than March 31, 2017, contingent on the extent of repairs required on each of the tanks. If a tank is taken out of service for an inspection, PHMSA agrees that an extension will be granted to allow Respondent to delay inspection for the next tank to be inspected, until the preceding tank is back in service. The intent of this extension is to prevent more than one tank at a time being taken out of service. 15. Respondent must create and submit on a quarterly basis a Consent Order Documentation Report (CODR). The intent is for the CODR to summarize all activities and documentation associated with this Order. The CODR should identify any activities or documentation for the period reflected in previous report activities; so the status of any item in the Order is reflected in each report. When the Respondent has concluded all required items in this Order, it will submit a final CODR to the Director. This will allow the Director to complete a thorough review of all actions taken by the Respondent with regard to this Order prior to approving the closure of this Order. 16. The Director may grant an extension of time for compliance with any of the terms of the Order upon a written request, timely submitted, demonstrating good cause for an extension. 17. ASIG may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator are final. IV. Review and Approval Process 18. With respect to any submission under Part III (Corrective Measures) of this Consent Agreement that requires the approval of the Region Director, the Director may: (a) approve, in whole or in part, the submission, (b) approve the submission on specified conditions; (c) disapprove, in whole or in part, the submission, or (d) any combination of the foregoing. If the Region Director approves, approves in part, or approves with conditions, Respondent will take all actions as approved by the Director, subject to Respondent’s right to invoke the dispute resolution procedures in Section V with respect to any conditions the Director identifies. If the Director disapproves all or any portion of the submission, the Director will provide Respondent with a written notice of the deficiencies. Respondent will correct all deficiencies within the time specified 4#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 8by the Director and resubmit it for approval, subject to the dispute resolution procedures in Section V. V. Dispute Resolution 19. The Region Director and Respondent will informally attempt to resolve any disputes arising under this Consent Agreement. If Respondent and the Region Director are unable to informally resolve the dispute within 15 days of submittal of Respondent’s invoking dispute resolution, Respondent may request in writing, within 10 days thereafter, a written determination resolving the dispute from the Associate Administrator for Pipeline Safety providing all information that Respondent believes is relevant to the dispute. If the request is submitted as provided herein, the Associate Administrator will issue a final determination in writing. The existence of a dispute and the PHMSA’s consideration of matters placed in dispute will not excuse, toll, or suspend any term or timeframe for completion of any work to be performed under this agreement during the pendency of the dispute resolution process except as reasonably agreed by the Region Director or the Associate Administrator in writing. VI. Enforcement 20. This Consent Agreement, as adopted by the Consent Order, is subject to all enforcement authorities available to the PHMSA under 49 U.S.C. § 60101 et seq. and 49 C.F.R. Part 190. All work plans and associated schedules set forth or referenced in Part III will be automatically incorporated into this Consent Agreement and are enforceable in the same manner. VII. Recordkeeping and Information Disclosure 21. Unless otherwise required by this Consent Agreement, Respondent agrees to maintain the material records demonstrating compliance with all requirements of this Consent Agreement for a period of at least 5 years following completion of all work to be performed. For any reports, plans or other deliverables required to be submitted to the PHMSA pursuant to this Consent Agreement, Respondent may assert a claim of business confidentiality or other protections applicable to the release of information by the PHMSA, covering part or all of the information required to be submitted to the PHMSA pursuant to this agreement in accordance with C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each page, and include a statement specifying the grounds for each claim of confidentiality. The PHMSA determines release of any information submitted pursuant to this Consent Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and/or the PHMSA policies, and other applicable regulations and Executive Orders. VIII. Effective Date 22. The “Effective Date” as used herein is the date on which the Order is issued by the Associate Administrator incorporating the terms of this Agreement. Unless specified to the contrary, all deadlines for actions required by this Consent Agreement run from the Effective Date of this Order. 5#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 9IX. Modification 23. The terms of this Consent Agreement may be modified by mutual agreement of the Parties. Such modifications must be in writing and signed by both parties. X. Termination 24. This Consent Agreement terminates upon completion of all terms set forth in Part III (Corrective Measures) as determined by the Director, Western Region. Respondent may request written confirmation from the PHMSA when this Consent Agreement is terminated and the Director, Western Region will provide such confirmation. To the extent ongoing monitoring is required, PHMSA may terminate this Consent Agreement with respect to all other requirements with the exception of such monitoring. Nothing in this Consent Agreement prevents Respondent from completing any of the obligations earlier than the deadlines provided for in this Agreement. XI. Ratification 25. The Parties’ undersigned representatives certify that they are fully authorized to enter into the terms and conditions of this Consent Agreement and to execute and legally bind such party to this document. 26. The Parties hereby agree to all conditions and terms of this Consent Agreement. 6#

520156002S_Consent Order and Agreement_05252016_text.pdf, page 10For Respondent: ________________________________ Lawrence McMahon Vice-President, Fuel Consortiums Aircraft Services International Group (ASIG) ________________________________ Date For PHMSA: ________________________________ Chris Hoidal Director, Office of Pipeline Safety PHMSA Western Region U.S. Department of Transportation ________________________________ Date 7#