{"operation":"document","citation":"CPF 520186003W","title":"AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-01-04","effective_on":null,"summary":"CLOSED warning letter citing 195.452(g), 195.452(i)(1), 195.452(i)(4), 195.452(j)(2), 195.452(j)(3), 195.452(j)(5)(i), 195.452(k), 195.452(l)(1)(ii), 195.49.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520186003W","body":"Warning Letter involving AIRCRAFT SERVICES INTERNATIONAL GROUP (ASIG). PHMSA's enforcement data identifies the cited regulations as 195.452(g),  195.452(i)(1),  195.452(i)(4),  195.452(j)(2),  195.452(j)(3),  195.452(j)(5)(i),  195.452(k),  195.452(l)(1)(ii),  195.49. The case was opened on 2018-01-04 and is reported as closed as of 2018-01-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520186003W_Warning Letter_01042018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186003W/520186003W_Warning%20Letter_01042018.pdf\n\n520186003W_Warning Letter_01042018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186003W/520186003W_Warning%20Letter_01042018_text.pdf\n\n520186003W_Warning Letter_01042018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 4, 2018\nMr. Trent Carbaugh\nGeneral Manager\nAircraft Service International Group\n6000 DeHavilland Drive,\nAnchorage, Alaska 99502\nCPF 5-2018-6003W\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 (U.S.C.),\ninspected your records associated with Aircraft Service International Group’s (ASIG’s)\nintegrity management program (IMP) 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 (CFR). The items\ninspected and the probable violations are:\n1. §195.49 Annual report.\nEach operator must annually complete and submit DOT Form PHMSA F 7000-\n1.1 for each type of hazardous liquid pipeline facility operated at the end of the\nprevious year. An operator must submit the annual report by June 15 each year,\nexcept that for the 2010 reporting year the report must be submitted by August\n15, 2011. A separate report is required for crude oil, HVL (including anhydrous\nammonia), petroleum products, carbon dioxide pipelines, and fuel grade ethanol\npipelines. For each state a pipeline traverses, an operator must separately\n\n\n\ncomplete those sections on the form requiring information to be reported for\neach state.\nIn the operator’s 2016 Annual Report, Subpart L did not list the correct mileage for High\nPopulation Areas (HPA), Other Populated Areas (OPA), and Drinking Water (DW). In the\n2016 Annual Report, Section 1.c Part F improperly indicated that a crack tool was used, but,\nin fact, no crack detection tool was used.\n2. §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(1) Information critical to determining the potential for, and preventing, damage\ndue to excavation, including current and planned damage prevention activities,\nand development or planned development along the pipeline segment;\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\n(4) Information about how a failure would affect the high consequence area, such\nas location of the water intake\nASIG failed to demonstrate that data gathered through the 2016 in-line inspection (ILI) and\nother inspections, tests, and surveillance patrols were integrated into the analysis of pipeline\nrisk.\n3. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(1) General requirements. An operator must take measures to prevent and\nmitigate the consequences of a pipeline failure that could affect a high\nconsequence area. These measures include conducting a risk analysis of the\npipeline segment to identify additional actions to enhance public safety or\nenvironmental protection. Such actions may include, but are not limited to,\nimplementing damage prevention best practices, better monitoring of cathodic\nprotection where corrosion is a concern, establishing shorter inspection intervals,\ninstalling EFRDs on the pipeline segment, modifying the systems that monitor\npressure and detect leaks, providing additional training to personnel on response\nprocedures, conducting drills with local emergency responders and adopting\nother management controls.\nThe ASIG’s 2015 IMP Section 3.0 states that the Quantitative Risk Assessment (QRA) will\ndrive the selection and implementation of Preventive and Mitigative Measures (P&MMs), but\n2\n\n\n\nASIG failed to demonstrate that the QRA determined the selection and implementation of\nP&MMs.\n4. §49 CFR 195.452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence 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 verbally stated that additional EFRD are not needed but failed to demonstrate an\nadequate risk-based analysis to substantiate that claim.\n5. §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).\nASIG failed to conduct and document the required periodic evaluations. Section 6.1.3 of the\nASIG’s 2015 IMP explains how the evaluation will be conducted and the minimum\nqualifications of the personnel conducting the evaluation. ASIG indicated that this was not\nfollowed.\n6. §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\n3\n\n\n\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.\nASIG stated that the 5-year interval was based on a comparison of the 2011 and the 2016\ndata, but lacked documentation to demonstrate that such a comparison had been made.\n7. §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 2011 and the 2016 assessments were conducted using magnetic flux leakage (MFL) and\ndeformation ILI tools. ASIG did not document the basis for determining that these are the\nmost appropriate tools for the integrity threats.\n8. §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.\nSection 8.2 of the ASIG’s 2015 IMP states how program evaluations will be conducted.\nASIG failed to measure the program’s effectiveness per their IMP.\n9. §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\n4\n\n\n\nactions taken, to implement and evaluate each element of the integrity\nmanagement program listed in paragraph (f) of this section.\nASIG failed to produce documentation consistent with the requirements of 195.452(I)(1)(ii).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a related series of violations. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in ASIG\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2018-6003W. 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\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano/J. Owens/H. Nguyen (#155057)\n5","truncated":false,"body_characters":11829}