HUNT CRUDE OIL SUPPLY CO — Notice of Amendment

220115008M_closure letter_06142011_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED June 14, 2011 Mr. N.C. Bowerman Vice President of Operations Hunt Crude Oil Supply Company P.O. Box 211 Gilbertown, AL 36908 CPF 2-2011-5008M Dear Mr. Bowerman: From December 13-17, 2010, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) written procedural manual for operations, maintenance, and emergencies at your Melvin, Alabama, pipeline office, pursuant to Chapter 601 of 49 United States Code. On the basis of the inspection, PHMSA issued a Notice of Amendment (NOA) on April 14, 2011. Hunt responded to the NOA in a letter dated May 6, 2011. The PHMSA Southern Region reviewed the written response and subsequently held several telephone conversations with Hunt personnel. As a result, we find Hunt’s response adequate. Therefore, this letter is to inform you that Hunt has complied with the terms of the NOA and that no further action is necessary with regards to the NOA. This case is now closed. Please be advised that this letter refers only to the NOA (CPF 2-2011-5008M) and not to any other PHMSA pending cases. Also be advised that nothing herein states or implies that the above described procedural manual meets the requirements of the federal pipeline safety regulations or that the procedural manual is approved. The Hunt pipeline system and the procedural manual remain subject to inspection by PHMSA. Sincerely, Wayne T. Lemoi Director, Office of Pipeline Safety PHMSA Southern Region#

220115008M_notice of amendment_04142011_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED April 14, 2011 Mr. N.C. Bowerman Vice President of Operations Hunt Crude Oil Supply Company P.O. Box 211 Gilbertown, AL 36908 CPF 2-2011-5008M Dear Mr. Bowerman: From December 13-17, 2010, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) written procedural manual for operations, maintenance, and emergencies at your Melvin, Alabama, pipeline office, pursuant to Chapter 601 of 49 United States Code. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Hunt’s procedures, as described below: 1. § 195.214 Welding procedures. (a) Welding must be performed by a qualified welder in accordance with welding procedures qualified under Section 5 of API 1104 or Section IX of the ASME Boiler and Pressure Vessel Code (incorporated by reference, see §195.3) . The quality of the test welds used to qualify the welding procedure shall be determined by destructive testing. (b) Each welding procedure must be recorded in detail, including the results of the qualifying tests. This record must be retained and followed whenever the procedure is used. Hunt’s Liquid Pipeline O&M Plan – August 2010, Procedure 6.10.1 was inadequate because it did not specify the correct edition and section of American Petroleum Institute (API) Standard 1104, Welding of Pipeline and Related Facilities, it would use to qualify welding procedures. Moreover, the procedure did not require Hunt to record the welding procedures in detail and include the results of the qualifying tests. 1#

220115008M_notice of amendment_04142011_text.pdf, page 22. § 195.222 Welders: Qualification of welders. (a) Each welder must be qualified in accordance with section 6 of API 1104 (incorporated by reference, see § 195.3) or section IX of the ASME Boiler and Pressure Vessel Code, (incorporated by reference, see § 195.3) except that a welder qualified under an earlier edition than listed in § 195.3 may weld but may not re- qualify under that earlier edition. Hunt’s Liquid Pipeline O&M Plan – August 2010, Procedure 6.10.1 was inadequate because it did not specify the correct edition or section of API Standard 1104 it would use to qualify welders. 3. § 195.571 What criteria must I use to determine the adequacy of cathodic protection? Cathodic protection required by this Subpart must comply with one or more of the applicable criteria and other considerations for cathodic protection contained in paragraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference, see § 195.3). Hunt’s Liquid Pipeline O&M Plan – August 2010, Procedure 7.9 was inadequate because it did not specify the correct edition of NACE International Standard Practice SP 0169, Control of External Corrosion on Underground or Submerged Metallic Piping Systems, it would use to determine the adequacy of its cathodic protection. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. 2#

220115008M_notice of amendment_04142011_text.pdf, page 3It is requested (not mandated) that Hunt maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Wayne Lemoi, Director, Southern Region, Office of Pipeline Safety, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 2-2011-5008M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Wayne T. Lemoi Director, Office of Pipeline Safety PHMSA Southern Region Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 3#