{"operation":"document","citation":"CPF 520166008W","title":"AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-10-26","effective_on":null,"summary":"CLOSED warning letter citing 194.113(b)(2), 195.403(b)(2), 195.452(g)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520166008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520166008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520166008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520166008W","body":"Warning Letter involving AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG). PHMSA's enforcement data identifies the cited regulations as 194.113(b)(2),  195.403(b)(2),  195.452(g)(2). The case was opened on 2016-10-26 and is reported as closed as of 2016-10-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520166008W_Warning Letter_10262016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520166008W/520166008W_Warning%20Letter_10262016.pdf\n\n520166008W_Warning Letter_10262016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520166008W/520166008W_Warning%20Letter_10262016_text.pdf\n\n520166008W_Warning Letter_10262016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 26, 2016\nMr. Lawrence McMahon\nVice-President, Fuel Consortiums\nAircraft Services International Group\nASIG/LAX Fuel\n9900 LAXfuel Road\nLos Angeles, CA 90045\nCPF 5-2016-6008W\nDear Mr. McMahon:\nOn August 1 through 4, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nAircraft Services International Group (ASIG) jet fuel pipeline between your tank facilities at\nthe Port of Anchorage and the Anchorage International Airport, and operation and\nmaintenance records associated with that pipeline in Anchorage, Alaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §194.113 Information summary.\n(b) The information summary for the response zone appendix, required in\n§194.107, must include:\n(2) The names or titles and 24-hour telephone numbers of the qualified\nindividual(s) and at least one alternate qualified individual(s);\n\n\n\nQualified Individual (QI) Trent Carbough's phone number was incorrect in the 2014 Facility\nResponse Plan; PHMSA verified by call out.\n2. §195.452 Pipeline integrity management in high consequence areas.\n(g) What is an information analysis? In periodically evaluating the integrity of\neach pipeline segment (paragraph (j) of this section), an operator must analyze\nall available information about the integrity of the entire pipeline and the\nconsequences of a failure. This information includes:\n(2) Data gathered through the integrity assessment required under this section;\nASIG personal did not complete Exposed Metal Piping Report forms during 2005 and 2007\ndigs that resulted from the integrity assessment surveys (in-line inspections). Personnel did\nnot document the dig location on the forms, and without spatial data it is impossible to\ncorrelate the results of the ultrasonic thickness and dent inspections done during the digs to\nresults of the in-line inspections.\n3. §195.403 Emergency response training.\n(b) At the intervals not exceeding 15 months, but at least once each calendar year,\neach operator shall:\n(2) Make appropriate changes to the emergency response training program as\nnecessary to ensure that it is effective.\nASIG did not adequately review the Emergency Response Manual at the required intervals in\n195.402(a), and did not make changes to the Emergency Response Plan as required by\n195.403(b)(2). Records indicate that the Emergency Response Plan was last reviewed in\nDecember 2012 and revised February 2013.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the items identified in this letter. Failure to do so will\nresult in ASIG being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2016-6008W. 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\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\n\n\n\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (#153333)","truncated":false,"body_characters":5193}