{"operation":"document","citation":"CPF 220115006W","title":"HUNT CRUDE OIL SUPPLY CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-04-06","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220115006W","body":"Warning Letter involving HUNT CRUDE OIL SUPPLY CO. PHMSA's enforcement data identifies the cited regulation as 195.452(f)(1). The case was opened on 2011-04-06 and is reported as closed as of 2011-04-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220115006W_Operator response_05062011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115006W/220115006W_Operator%20response_05062011.pdf\n\n220115006W_warning letter_04062011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115006W/220115006W_warning%20letter_04062011.pdf\n\n220115006W_warning letter_04062011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115006W/220115006W_warning%20letter_04062011_text.pdf\n\n220115006W_warning letter_04062011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 6, 2011\nN.C. Bowerman\nVice President of Operations\nHunt Crude Oil Supply Company\nP.O. Box 211\nGilbertown, AL 36908\nCPF 2-2011-5006W\nDear Mr. Bowerman:\nOn February 7-10, 2011, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) Liquid\nIntegrity Management Program in Melvin, Alabama, pursuant to Chapter 601 of 49 United\nStates Code.\nAs a result of the inspection, it appears that Hunt has committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and\nthe probable violation is:\n1. §195.452(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 drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) A process for identifying which pipeline segments could affect a high consequence\narea;\nHunt failed to identify certain pipeline facilities that could affect a high consequence area\n(HCA). Section 2.3 and Appendix O (page O-2) in Hunt’s liquid integrity management\nprogram dated March 2010 have guidance Hunt should use to determine if facilities could\naffect a high consequence area. Yet, Hunt’s liquid integrity management program\ndocumentation did not show that Hunt had completed an evaluation to determine if two\nbreakout tanks located in Melvin, Alabama, or the Boligee Pump Station at mile post 63 in\nAlabama could affect an HCA.\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item(s) identified in this letter. Failure to do so will result in Hunt Crude Oil Supply\nCompany 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 2-2011-5006W. 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,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n2","truncated":false,"body_characters":3981}