# HUNT CRUDE OIL SUPPLY CO — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 195.452(f)(1).
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- **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.

Official case documents:

220115006W_Operator response_05062011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115006W/220115006W_Operator%20response_05062011.pdf

220115006W_warning letter_04062011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115006W/220115006W_warning%20letter_04062011.pdf

220115006W_warning letter_04062011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115006W/220115006W_warning%20letter_04062011_text.pdf

220115006W_warning letter_04062011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 6, 2011
N.C. Bowerman
Vice President of Operations
Hunt Crude Oil Supply Company
P.O. Box 211
Gilbertown, AL 36908
CPF 2-2011-5006W
Dear Mr. Bowerman:
On February 7-10, 2011, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) Liquid
Integrity Management Program in Melvin, Alabama, pursuant to Chapter 601 of 49 United
States Code.
As a result of the inspection, it appears that Hunt has committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and
the probable violation is:
1. §195.452(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions drawn
from results of the integrity assessments, and other maintenance and surveillance
data, and evaluation of consequences of a failure on the high consequence area. An
operator must include, at minimum, each of the following elements in its written
integrity management program:
(1) A process for identifying which pipeline segments could affect a high consequence
area;
Hunt failed to identify certain pipeline facilities that could affect a high consequence area
(HCA). Section 2.3 and Appendix O (page O-2) in Hunt’s liquid integrity management
program dated March 2010 have guidance Hunt should use to determine if facilities could
affect a high consequence area. Yet, Hunt’s liquid integrity management program
documentation did not show that Hunt had completed an evaluation to determine if two
breakout tanks located in Melvin, Alabama, or the Boligee Pump Station at mile post 63 in
Alabama could affect an HCA.



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(s) identified in this letter. Failure to do so will result in Hunt Crude Oil Supply
Company being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 2-2011-5006W. 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
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