{"operation":"document","citation":"CPF 520186002M","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":"2018-01-04","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(1), 195.452(f)(8), 195.452(g)(2), 195.452(g)(3), 195.452(h)(1), 195.452(h)(1)(ii), 195.452(h)(2), 195.452(h)(4)(i)(b), 195.452(h)(4)(iii)(g), 195.452(i)(2), 195.452(i)(4), 195.452(j)(2), 195.452(j)(3), 195.452(j)(4), 195.452(j)(5)(i), 195.452(j)(5)(iv), 195.452(k), 195.452(l)(ii), 195.505(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520186002M","body":"Notice of Amendment involving AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG). PHMSA's enforcement data identifies the cited regulations as 195.452(f)(1),  195.452(f)(8),  195.452(g)(2),  195.452(g)(3),  195.452(h)(1),  195.452(h)(1)(ii),  195.452(h)(2),  195.452(h)(4)(i)(b),  195.452(h)(4)(iii)(g),  195.452(i)(2),  195.452(i)(4),  195.452(j)(2),  195.452(j)(3),  195.452(j)(4),  195.452(j)(5)(i),  195.452(j)(5)(iv),  195.452(k),  195.452(l)(ii),  195.505(a). The case was opened on 2018-01-04 and is reported as closed as of 2019-01-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520186002M_Closure Letter_01152019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186002M/520186002M_Closure%20Letter_01152019.pdf\n\n520186002M_Closure Letter_01152019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186002M/520186002M_Closure%20Letter_01152019_text.pdf\n\n520186002M_Notice of Amendment_01042018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186002M/520186002M_Notice%20of%20Amendment_01042018.pdf\n\n520186002M_Notice of Amendment_01042018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186002M/520186002M_Notice%20of%20Amendment_01042018_text.pdf\n\n520186002M_Operator Response to Notice_07052018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186002M/520186002M_Operator%20Response%20to%20Notice_07052018.pdf\n\n520186002M_Notice of Amendment_01042018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 4, 2018\nMr. Trent Carbaugh\nGeneral Manager\nAircraft Service International Group\n6000 DeHavilland Drive\nAnchorage, Alaska 99502\nCPF 5-2018-6002M\nDear Mr. Carbaugh:\nOn July 11 through 13, 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nAircraft Service International Group’s (ASIG’s) Integrity Management Plan (IMP), and\nportions of other procedures which are incorporated in the IMP, in Anchorage, Alaska.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within\nASIG’s plans or procedures, as described below:\n1. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(1) A process for identifying which pipeline segments could affect a high\n\n\n\nconsequence area;\nASIG failed to identify in their 2015 Integrity Management Plan (IMP) all pipeline segments\nthat could affect a high consequence area (HCA). Section 1.1 of the IMP states that the IMP\ncovers the pipeline from the pig launcher to the pig receiver, but fails to identify other\npipeline facilities that could affect an HCA, specifically the breakout tank at the Airport\nFacility and the pump station at the Off-Airport Facility. ASIG must amend their IMP to\nidentify all pipeline segments that could affect an HCA.\n2. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(8) A process for review of integrity assessment results and information analysis\nby a person qualified to evaluate the results and information (see paragraph\n(h)(2) of this section).\nASIG’s 2015 IMP lacks an adequate process for review of the integrity assessment results and\ninformation analysis in accordance with §49 CFR 195.452(f)(8). In-line inspection (ILI)\nresults must be reviewed by personnel qualified in accordance with ANSI/ASNT ILI-\nPQ, Inline Inspection Personnel Qualification and Certification, as required by §49 CFR\n195.591. ASIG must amend their IMP to include a process for reviewing ILI integrity\nassessments by personnel qualified in accordance with ANSI/ASNT ILI-PQ.\n3. §49 CFR 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;\n(3) Data gathered in conjunction with other inspections, tests, surveillance and\npatrols required by this Part, including, corrosion control monitoring and\ncathodic protection surveys; and\nASIG’s 2015 IMP lacks an adequate process for conducting information analysis. In Section\n3 of the 2015 IMP, ASIG presents the information analysis in the form of a Quantitative Risk\nAssessment (QRA).\n The QRA was prepared in 2015. ASIG failed to update the QRA to reflect data\ngathered through assessments and other inspections conducted since 2015. ASIG\nmust amend their IMP to include a process for integrating new assessment/evaluation\n2\n\n\n\ndata into the QRA.\n The 2015 IMP’s QRA is insufficient to support a risk-based evaluation and assessment\nprocess, as required by §49 CFR 195.452 (j)(2) and (j)(3). The QRA failed to analyze\nall risk factors (e.g. cracking, cyclic fatigue); failed to validate or justify each risk\nfactor; and failed to consider both the probability and consequence of failure. ASIG\nmust amend their information analysis process to ensure that it produces an adequate\nrisk model to support a risk-based evaluation and assessment process.\n4. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(1) General requirements. An operator must take prompt action to address all\nanomalous conditions the operator discovers through the integrity assessment or\ninformation analysis. In addressing all conditions, an operator must evaluate all\nanomalous conditions and remediate those that could reduce a pipeline's\nintegrity. An operator must be able to demonstrate that the remediation of the\ncondition will ensure the condition is unlikely to pose a threat to the long-term\nintegrity of the pipeline. An operator must comply with §195.422 when making a\nrepair.\nASIG’s 2015 IMP and Operations and Maintenance (O&M) manual lack an adequate process\nfor conducting pressure reductions per §49 CFR 195.452(h)(1)(i) and (h)(1)(ii). ASIG must\namend the IMP and/or O&M manual to include a process for determining the correct reduced\noperation pressure and adjusting appropriate set points such as mainline Pressure Safety\nValves (PSVs), thermal relief PSVs and pressure alarms.\n5. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(1) General requirements. An operator must take prompt action to address all\nanomalous conditions the operator discovers through the integrity assessment or\ninformation analysis. In addressing all conditions, an operator must evaluate all\nanomalous conditions and remediate those that could reduce a pipeline's\nintegrity. An operator must be able to demonstrate that the remediation of the\ncondition will ensure the condition is unlikely to pose a threat to the long-term\nintegrity of the pipeline. An operator must comply with §195.422 when making a\nrepair.\n(ii) Long-term pressure reduction. When a pressure reduction exceeds 365 days,\nthe operator must notify PHMSA in accordance with paragraph (m) of this\nsection and explain the reasons for the delay. An operator must also take further\nremedial action to ensure the safety of the pipeline.\nASIG’s 2015 IMP does not identify the correct PHMSA contact notifications for temporary\npressure reductions and long-term pressure reductions in accordance with §49 CFR\n195.452(h)(1)(i) and (ii). To ensure that PHMSA is correctly notified, ASIG must amend their\nIMP to include the contacts specified in §49 CFR 195.452(m)(1) and (m)(2). In addition,\nsome conditions which require IM notifications may also be Safety Related Conditions\n3\n\n\n\nrequiring separate notification in accordance with 49 CFR 195.56. To ensure both\nnotifications are done correctly, the IMP should clearly state when such conditions exist.\n6. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(2) Discovery of condition. Discovery of a condition occurs when an operator has\nadequate information about the condition to determine that the condition\npresents a potential threat to the integrity of the pipeline. An operator must\npromptly, but no later than 180 days after an integrity assessment, obtain\nsufficient information about a condition to make that determination, unless the\noperator can demonstrate that the 180-day period is impracticable.\nASIG’s 2105 IMP lacks an adequate process for collecting adequate information to determine\n“discovery of condition” following an integrity assessment. ASIG stated that ILI is their\npreferred integrity assessment method. ASIG must amend the IMP to include a process\nconsistent with API Standard 1163, Inline Inspection Systems Qualification Standard,\n(incorporated by reference in §49 CFR 195.3) to obtain sufficient information about a\ncondition that presents a potential threat. The process must explain, consistent with API\n1163, how verification and validation will be conducted and how tool tolerances will be\nconsidered.\n7. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(4) Special requirements for scheduling remediation—\n(i) Immediate repair conditions. An operator's evaluation and remediation\nschedule must provide for immediate repair conditions. To maintain safety, an\noperator must temporarily reduce the operating pressure or shut down the\npipeline until the operator completes the repair of these conditions. An operator\nmust calculate the temporary reduction in operating pressure using the formulas\nreferenced in paragraph (h)(4)(i)(B) of this section. If no suitable remaining\nstrength calculation method can be identified, an operator must implement a\nminimum 20 percent or greater operating pressure reduction, based on actual\noperating pressure for two months prior to the date of inspection, until the\nanomaly is repaired. An operator must treat the following conditions as\nimmediate repair conditions:\n(B) A calculation of the remaining strength of the pipe shows a predicted burst\npressure less than the established maximum operating pressure at the location of\nthe anomaly. Suitable remaining strength calculation methods include, but are\nnot limited to, ASME/ANSI B31G (incorporated by reference, see §195.3) and\nPRCI PR-3-805 (R-STRENG) (incorporated by reference, see §195.3).\nASIG’s 2015 IMP lacks an adequate process to determine the remaining strength of the pipe.\nSection 5.1.1 of the IMP states that the pressure reduction will be taken in accordance with\nB31.4 and does not reference B31G or R-STRENG, which are the allowable methods to\ncalculate the reduced operating pressure. ASIG must amend their IMP to specify the\nremaining strength calculation methods incorporated in §49 CFR 195.452(h)(4)(1)(B).\n4\n\n\n\n8. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(4) Special requirements for scheduling remediation—\n(iii) 180-day conditions. Except for conditions listed in paragraph (h)(4)(i) or (ii)\nof this section, an operator must schedule evaluation and remediation of the\nfollowing within 180 days of discovery of the condition:\n(G) A potential crack indication that when excavated is determined to be a crack.\nASIG’s 2015 IMP and repair procedures lack a process for conducting non-destructive testing\nto determine if a potential indication is a crack, and lacks a process for determining which\nrepair procedures are appropriate for remediating a crack. ASIG must amend their procedures\nwith a process to evaluate potential cracks and must specify which of the repair methods in\ntheir O&M manual are acceptable to remediate cracks.\n9. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\nWhat preventive and mitigative measures must an operator take to protect the high\nconsequence area?\n(2) Risk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the likelihood of a pipeline\nrelease occurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited\nto:\nASIG’s 2015 IMP lacks an adequate process for “conducting a risk analysis of the pipeline\nsegment to identify additional actions to enhance public safety or environmental protection.”\nThe QRA in Section 3.1 of the IMP lacks sufficient details for identifying Preventative and\nMitigative Measures. Specifically, the QRA failed to consider probability and consequence\nfactors in creating a risk score; it failed to consider the breakout tank at airport facility and the\npump station at off-airport facility; and failed to consider all relevant risk factors (e.g.\ncracking, cyclic fatigue).\n10. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\nWhat preventive and mitigative measures must an operator take to protect the high\nconsequence area?\n(4) Emergency Flow Restricting Devices (EFRD). If an operator determines that\nan EFRD is needed on a pipeline segment to protect a high consequence area in\nthe event of a hazardous liquid pipeline release, an operator must install the\nEFRD. In making this determination, an operator must, at least, consider the\nfollowing factors—the swiftness of leak detection and pipeline shutdown\ncapabilities, the type of commodity carried, the rate of potential leakage, the\nvolume that can be released, topography or pipeline profile, the potential for\nignition, proximity to power sources, location of nearest response personnel,\nspecific terrain between the pipeline segment and the high consequence area, and\nbenefits expected by reducing the spill size.\nASIG’s 2015 IMP lacks a risk-based process which adequately considers all the cited factors\n5\n\n\n\nfor determining the need for additional EFRDs and must be amended to include such a\nprocess.\n11. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity? —\n(2) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure pipeline integrity. An operator must base the frequency of\nevaluation on risk factors specific to its pipeline, including the factors specified in\nparagraph (e) of this section. The evaluation must consider the results of the\nbaseline and periodic integrity assessments, information analysis (paragraph (g)\nof this section), and decisions about remediation, and preventive and mitigative\nactions (paragraphs (h) and (i) of this section).\nThe 2015 IMP lacks an adequate process for conducting continuing evaluation to assure\npipeline integrity. The IMP Section 6.1.3 states that evaluation of the data will be conducted\n“When required by this program,” but lacks an adequate process to determine how that\nevaluation interval will be determined. ASIG must amend their IMP to include a process to\nensure that evaluation is done “as frequently as needed.” The 2015 IMP lacks a process for\nconducting continuing evaluation at pipeline facilities including the breakout tank at the\nAirport Facility and the pump station at the Off-Airport Facility. The IMP must be amended\nto include a process for conducting continuing evaluation to assure pipeline integrity.\n12. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity? —\n(3) Assessment intervals. An operator must establish five-year intervals, not to\nexceed 68 months, for continually assessing the line pipe's integrity. An operator\nmust base the assessment intervals on the risk the line pipe poses to the high\nconsequence area to determine the priority for assessing the pipeline segments.\nAn operator must establish the assessment intervals based on the factors\nspecified in paragraph (e) of this section, the analysis of the results from the last\nintegrity assessment, and the information analysis required by paragraph (g) of\nthis section.\nThe 2015 IMP lacks a process to determine the appropriate assessment interval. Section 6.1.2\nof the IMP states “The selection of tool type and frequency will be based on the results of the\nprevious inspection and a review of the Best-Available Technology at the time of the re-\nevaluation.” ASIG must amend their IMP to include a process for determining assessment\nintervals that is consistent with §49 CFR 195.452(j)(3).\n13. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity? —\n(4) Variance from the 5-year intervals in limited situations—\n6\n\n\n\nThe IMP does not include an adequate process to notify the Office of Pipeline Safety (OPS)\nbefore variance from the 5-year inspection intervals per §49 CFR 195.452(j)(4). To ensure\nthat PHMSA is correctly notified, ASIG must include the contacts specified in §49 CFR\n195.452(m)(1) and (m)(2).\n14. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity? —\n(5) Assessment methods. An operator must assess the integrity of the line pipe by\nany of the following methods. The methods an operator selects to assess low\nfrequency electric resistance welded pipe or lap welded pipe susceptible to\nlongitudinal seam failure must be capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n(i) In-Line Inspection tool or tools capable of detecting corrosion and\ndeformation anomalies, including dents, gouges, and grooves. For pipeline\nsegments that are susceptible to cracks (pipe body and weld seams), an operator\nmust use an in-line inspection tool or tools capable of detecting crack anomalies.\nWhen performing an assessment using an In-Line Inspection tool, an operator\nmust comply with §195.591;\nThe 2015 IMP lacks an adequate process for selecting an assessment method (per §49 CFR\n195.452(j)(5)) based on the integrity threats identified in the risk assessment and information\nanalysis. The IMP indicates that in-line inspection is the preferred assessment method, but\ndoes not include a process for selecting an appropriate ILI tool type with adequate\nperformance specifications. ASIG must amend their IMP to include a process that is\nconsistent with NACE SP0102‐2010, and API 1163 (incorporated by reference in §49 CFR\n195.3) to select an appropriate ILI tool(s), determining appropriate tool specifications, and\nconducting the ILI assessment.\n15. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity? —\n(5) Assessment methods. An operator must assess the integrity of the line pipe by\nany of the following methods. The methods an operator selects to assess low\nfrequency electric resistance welded pipe or lap welded pipe susceptible to\nlongitudinal seam failure must be capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n(iv) Other technology that the operator demonstrates can provide an equivalent\nunderstanding of the condition of the line pipe. An operator choosing this option\nmust notify OPS 90 days before conducting the assessment, by sending a notice to\nthe address or facsimile number specified in paragraph (m) of this section.\nThe IMP does not include an adequate process to notify OPS before conducting assessments\nwith other technologies. To ensure that PHMSA is correctly notified, ASIG must include the\ncontacts specified in §49 CFR 195.452(m)(1) and (m)(2).\n7\n\n\n\n16. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(k) What methods to measure program effectiveness must be used? An operator's\nprogram must include methods to measure whether the program is effective in\nassessing and evaluating the integrity of each pipeline segment and in protecting\nthe high consequence areas. See Appendix C of this part for guidance on methods\nthat can be used to evaluate a program's effectiveness.\nASIG’s IMP lacks an adequate process for measuring the program’s effectiveness. Section\n8.1 of the IMP states that certain criteria can be used for measuring the program’s\neffectiveness and lists three categories of performance measures, but the categories are overly\nbroad and do not provide sufficient metrics of the program’s performance. ASIG must amend\ntheir IMP to select metrics that are appropriate for their system, and specify how often these\nperformance metrics will be evaluated and how the results will be used.\n17. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(l) What records must an operator keep to demonstrate compliance?\n(ii) Documents to support the decisions and analyses, including any\nmodifications, justifications, deviations and determinations made, variances, and\nactions taken, to implement and evaluate each element of the integrity\nmanagement program listed in paragraph (f) of this section.\nASIG’s 2015 IMP lacks a process to create and retain documentation consistent with §49\nCFR 195.452(l)(ii). Section 9.0 of the IMP lacks most of the elements of this code section.\nASIG must amend their IMP to include a process for creating and retaining the required\ndocuments.\n18. §49 CFR 195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The\nprogram shall include provisions to:\n(a) Identify covered tasks\nASIG’s Operator Qualification (OQ) task for “JFP Pigging Procedures” (Task JFP 04) is\nspecific to launching and receiving a cleaning pig, but does not include the additional tasks\nassociated with the launching and receiving in-line inspection (ILI) tools that are described in\ntheir “Inspection Pig Procedures.” ASIG’s must amend their written OQ program to include\ntasks associated with the ILI process.\n8\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §\n190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 180 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have\nbeen addressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that ASIG maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Kim West, Acting Director, Western Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 5-2018-6002M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (# 155057)\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n9\n\n520186002M_Closure Letter_01152019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 15, 2019\nMr. Trent Carbaugh\nGeneral Manager\nMenzies Aviation\n6000 De Havilland Drive\nAnchorage, AK 99508\nCPF 5-2018-6002M\nClosure Letter\nDear Mr Carbaugh:\nFrom July 11 through 13, 2017, representatives from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted\nan on-site pipeline safety inspection of Aircraft Services International Group’s (ASIG) Integrity\nManagement Plan (IMP), and portions of other procedures which are incorporated in the IMP, in\nAnchorage, Alaska. As a result of the inspection, ASIG was issued a Notice of Amendment on\nJanuary 4, 2018, which proposed amendments of your procedures. Menzies Aviation is now the\noperator of the ASIG facilites in Anchorage.\nMenzies Aviation submitted its amended procedures on July 5, 2018 and December 10, 2018.\nMy staff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":27083}