# HUNT CRUDE OIL SUPPLY CO — Warning Letter

**Citation:** CPF 220125009W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2012-07-25

CLOSED warning letter citing 195.440(a), 195.440(d)(2), 195.440(i).

## Document text

Warning Letter involving HUNT CRUDE OIL SUPPLY CO. PHMSA's enforcement data identifies the cited regulations as 195.440(a),  195.440(d)(2),  195.440(i). The case was opened on 2012-07-25 and is reported as closed as of 2012-07-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220125009W_warning letter_07252012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125009W/220125009W_warning%20letter_07252012.pdf

220125009W_warning letter_07252012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125009W/220125009W_warning%20letter_07252012_text.pdf

220125009W_warning letter_07252012_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 25, 2012
Mr. Joe Giglotto
Senior Vice President Operations
Hunt Crude Oil Supply Company
2200 Jack Warner Pkwy., Suite 400
Tuscaloosa, AL 35401
CPF 2-2012-5009W
Dear Mr. Giglotto:
From June 4-5, 2012, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) inspected Hunt Crude Oil Supply Company’s (Hunt) Public
Awareness Program at your Tuscaloosa, AL refinery office pursuant to Chapter 601 of 49
United States Code.
As a result of the inspection, it appears that Hunt has committed probable violations of the
Pipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The items
inspected and the probable violations are as follows:
1. §195.440 Public awareness.
(a) Each pipeline operator must develop and implement a written continuing public
education program that follows the guidance provided in the American Petroleum
Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see
§195.3).
Hunt did not provide information on emergency preparedness communications in its
baseline messages to Emergency Officials or Public Officials in accordance with
API 1162, Table 2-1 Summary Public Awareness Communications for Hazardous Liquids
and Natural Gas Transmission Pipeline Operators. The letter and brochure Hunt
provided to Emergency Responders and Public Officials instructs them to, “From a safe
location, call 9-1-1 or local EMS and the pipeline company, giving your name, phone
number, leak description and location.” While this message may be appropriate for the
Affected Public, it is not appropriate for Emergency Officials and Public Officials
possibly responding to a pipeline incident.



2. §195.440 Public awareness.
(a) Each pipeline operator must develop and implement a written continuing public
education program that follows the guidance provided in the American Petroleum
Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see
§195.3).
Hunt did not provide baseline messages in 2008 to all of its Affected Public audience in
accordance with API 1162, Table 2-1 Summary Public Awareness Communications for
Hazardous Liquids and Natural Gas Transmission Pipeline Operators. While the
brochure for the Affected Public was mailed to the Affected Public audience in
Mississippi in 2008, it was not mailed to Affected Public audience in Alabama.
3. §195.440 Public awareness.
… (d) The operator's program must specifically include provisions to educate the
public, appropriate government organizations, and persons engaged in excavation
related activities on:
… (2) Possible hazards associated with unintended releases from a hazardous liquid
or carbon dioxide pipeline facility;
Hunt did not provide information in its baseline message to the Affected Public on the
possible hazards associated with an unintended release of product from its hazardous
liquid pipeline facility. That is, the brochure Hunt sent to the Affected Public did not
contain any information on the hazards associated with an unintended release from the
Hunt hazardous liquid pipeline.
4. §195.440 Public awareness.
… (i) The operator's program documentation and evaluation results must be
available for periodic review by appropriate regulatory agencies.
Hunt did not have adequate documentation to demonstrate that the 2006 baseline message
material for the Affected Public was delivered in accordance with API 1162, Table 2-1
Summary Public Awareness Communications for Hazardous Liquids and Natural Gas
Transmission Pipeline Operators. In 2006, Hunt contracted with Paradigm to deliver the
baseline message to the Affected Public by mailing a brochure via the U.S Postal
Service. Hunt did not have records, such as postal records or mailing lists, to adequately
document that the mailings were completed.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of
$1,000,000 for any related series of violations. We have reviewed the circumstances and
supporting documents involved in this case, and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time. We advise you to
correct the item identified in this letter. Failure to do so will result in Hunt Crude Oil
Supply Company being subject to additional enforcement action.
2



No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 2-2012-5009W. 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).
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/220125009W>
- Source ID: `phmsa-enforcement`
- SHA-256: `ac02e8e326466b26ed011f4af1f85b893b5ee173001e373c2652bcd9e7254668`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T22:03:24.387Z
- Document slug: `phmsa-enforcement-220125009w`

### Source metadata

```json
{
  "cpf": "220125009W",
  "operator": "HUNT CRUDE OIL SUPPLY CO",
  "region": "Southern",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.440(a)",
    "195.440(d)(2)",
    "195.440(i)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
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      "bytes": 272941,
      "category": "agency_document"
    },
    {
      "name": "220125009W_warning letter_07252012_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/220125009W/220125009W_warning%20letter_07252012_text.pdf",
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  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "HUNT CRUDE OIL SUPPLY CO"
}
```
