{"operation":"document","citation":"CPF 220115008M","title":"HUNT CRUDE OIL SUPPLY CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-04-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.214(a), 195.222(a), 195.571.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220115008M","body":"Notice of Amendment involving HUNT CRUDE OIL SUPPLY CO. PHMSA's enforcement data identifies the cited regulations as 195.214(a),  195.222(a),  195.571. The case was opened on 2011-04-14 and is reported as closed as of 2011-06-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220115008M_closure letter_06142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115008M/220115008M_closure%20letter_06142011.pdf\n\n220115008M_closure letter_06142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115008M/220115008M_closure%20letter_06142011_text.pdf\n\n220115008M_notice of amendment_04142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115008M/220115008M_notice%20of%20amendment_04142011.pdf\n\n220115008M_notice of amendment_04142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115008M/220115008M_notice%20of%20amendment_04142011_text.pdf\n\n220115008M_closure letter_06142011_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 14, 2011\nMr. N.C. Bowerman\nVice President of Operations\nHunt Crude Oil Supply Company\nP.O. Box 211\nGilbertown, AL 36908\nCPF 2-2011-5008M\nDear Mr. Bowerman:\nFrom December 13-17, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) written\nprocedural manual for operations, maintenance, and emergencies at your Melvin, Alabama,\npipeline office, pursuant to Chapter 601 of 49 United States Code. On the basis of the\ninspection, PHMSA issued a Notice of Amendment (NOA) on April 14, 2011.\nHunt responded to the NOA in a letter dated May 6, 2011. The PHMSA Southern Region\nreviewed the written response and subsequently held several telephone conversations with\nHunt personnel. As a result, we find Hunt’s response adequate. Therefore, this letter is to\ninform you that Hunt has complied with the terms of the NOA and that no further action is\nnecessary with regards to the NOA. This case is now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2011-5008M) and not to any\nother PHMSA pending cases. Also be advised that nothing herein states or implies that the\nabove described procedural manual meets the requirements of the federal pipeline safety\nregulations or that the procedural manual is approved. The Hunt pipeline system and the\nprocedural manual remain subject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220115008M_notice of amendment_04142011_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 14, 2011\nMr. N.C. Bowerman\nVice President of Operations\nHunt Crude Oil Supply Company\nP.O. Box 211\nGilbertown, AL 36908\nCPF 2-2011-5008M\nDear Mr. Bowerman:\nFrom December 13-17, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) written\nprocedural manual for operations, maintenance, and emergencies at your Melvin, Alabama,\npipeline office, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nHunt’s procedures, as described below:\n1. § 195.214 Welding procedures.\n(a) Welding must be performed by a qualified welder in accordance with welding\nprocedures qualified under Section 5 of API 1104 or Section IX of the ASME Boiler\nand Pressure Vessel Code (incorporated by reference, see §195.3) . The quality of the\ntest welds used to qualify the welding procedure shall be determined by destructive\ntesting.\n(b) Each welding procedure must be recorded in detail, including the results of the\nqualifying tests. This record must be retained and followed whenever the procedure\nis used.\nHunt’s Liquid Pipeline O&M Plan – August 2010, Procedure 6.10.1 was inadequate\nbecause it did not specify the correct edition and section of American Petroleum Institute\n(API) Standard 1104, Welding of Pipeline and Related Facilities, it would use to qualify\nwelding procedures. Moreover, the procedure did not require Hunt to record the welding\nprocedures in detail and include the results of the qualifying tests.\n1\n\n\n\n2. § 195.222 Welders: Qualification of welders.\n(a) Each welder must be qualified in accordance with section 6 of API 1104\n(incorporated by reference, see § 195.3) or section IX of the ASME Boiler and\nPressure Vessel Code, (incorporated by reference, see § 195.3) except that a welder\nqualified under an earlier edition than listed in § 195.3 may weld but may not re-\nqualify under that earlier edition.\nHunt’s Liquid Pipeline O&M Plan – August 2010, Procedure 6.10.1 was inadequate\nbecause it did not specify the correct edition or section of API Standard 1104 it would use\nto qualify welders.\n3. § 195.571 What criteria must I use to determine the adequacy of cathodic\nprotection?\nCathodic protection required by this Subpart must comply with one or more of the\napplicable criteria and other considerations for cathodic protection contained in\nparagraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference, see § 195.3).\nHunt’s Liquid Pipeline O&M Plan – August 2010, Procedure 7.9 was inadequate because\nit did not specify the correct edition of NACE International Standard Practice SP 0169,\nControl of External Corrosion on Underground or Submerged Metallic Piping Systems, it\nwould use to determine the adequacy of its cathodic protection.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 30 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\n2\n\n\n\nIt is requested (not mandated) that Hunt maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Wayne Lemoi, Director, Southern Region, Office of\nPipeline Safety, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 2-2011-5008M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":7850}