{"operation":"document","citation":"CPF 220115007W","title":"HUNT CRUDE OIL SUPPLY CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-04-08","effective_on":null,"summary":"CLOSED warning letter citing 195.406(a)(3), 195.573(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220115007W","body":"Warning Letter involving HUNT CRUDE OIL SUPPLY CO. PHMSA's enforcement data identifies the cited regulations as 195.406(a)(3),  195.573(d). The case was opened on 2011-04-08 and is reported as closed as of 2011-04-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220115007W_Operator response_05062011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115007W/220115007W_Operator%20response_05062011.pdf\n\n220115007W_Warning Letter_04082011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115007W/220115007W_Warning%20Letter_04082011.pdf\n\n220115007W_Warning Letter_04082011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115007W/220115007W_Warning%20Letter_04082011_text.pdf\n\n220115007W_Warning Letter_04082011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 8, 2011\nMr. N.C. Bowerman\nVice President of Operations\nHunt Crude Oil Supply Company\nP.O. Box 211\nGilbertown, AL 36908\nCPF 2-2011-5007W\nDear Mr. Bowerman:\nOn December 13-17, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) pipeline\nsystem in Melvin, Alabama, pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that Hunt has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. § 195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n.... (3) Eighty percent of the test pressure for any part of the pipeline which has been\npressure tested under subpart E of this part.\nHunt did not meet the regulation because the maximum operating pressure (MOP) it\nestablished on its pipeline system, 1286 psig, exceeded 80% of the lowest pressure\nrecorded during the hydrostatic pressure test it used to determine the MOP.\nHunt’s hydrostatic pressure test records indicated that the lowest recorded pressure was\n1593 psig and that the highest recorded pressure was 1607 psig. Hunt established its\nMOP as 80% of the highest pressure, not 80% of the lowest pressure, as required by the\nregulations. This resulted in the MOP being established as 1286 psig; 12 psig above the\nproper value of 1274 psig.\n\n\n\nIt should be noted that the normal safe operating pressure of the Hunt pipeline is around\n900 psig, which is the maximum pressure that can be applied to the pipeline due to the\nconfiguration of the pumping equipment. There was no indication in the records that Hunt\nhad ever approached or exceeded the MOP of its pipeline.\n2. § 195.573 What must I do to monitor external corrosion control?\n... (d) Breakout tanks. You must inspect each cathodic protection system used to\ncontrol corrosion on the bottom of an aboveground breakout tank to ensure that\noperation and maintenance of the system are in accordance with API Recommended\nPractice 651. However, this inspection is not required if you note in the corrosion\ncontrol procedures established under § 195.402(c)(3) why compliance with all or\ncertain operation and maintenance provisions of API Recommended Practice 651 is\nnot necessary for the safety of the tank.\nHunt did not take structure-to-soil cathodic protection readings on the two 80,000 bbl.\naboveground breakout tanks located at Melvin Station. Hunt’s last recorded cathodic\nprotection inspection of these breakout tanks was in 2002. API Recommended Practice\n651 recommends that these surveys be done annually.\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 items 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 2-2011-5007W. 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":4999}