{"operation":"document","citation":"CPF 220125009W","title":"HUNT CRUDE OIL SUPPLY CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-07-25","effective_on":null,"summary":"CLOSED warning letter citing 195.440(a), 195.440(d)(2), 195.440(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220125009W","body":"Warning Letter involving HUNT CRUDE OIL SUPPLY CO. PHMSA's enforcement data identifies the cited regulations as 195.440(a),  195.440(d)(2),  195.440(i). The case was opened on 2012-07-25 and is reported as closed as of 2012-07-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220125009W_warning letter_07252012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125009W/220125009W_warning%20letter_07252012.pdf\n\n220125009W_warning letter_07252012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125009W/220125009W_warning%20letter_07252012_text.pdf\n\n220125009W_warning letter_07252012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 25, 2012\nMr. Joe Giglotto\nSenior Vice President Operations\nHunt Crude Oil Supply Company\n2200 Jack Warner Pkwy., Suite 400\nTuscaloosa, AL 35401\nCPF 2-2012-5009W\nDear Mr. Giglotto:\nFrom June 4-5, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected Hunt Crude Oil Supply Company’s (Hunt) Public\nAwareness Program at your Tuscaloosa, AL refinery office pursuant to Chapter 601 of 49\nUnited States Code.\nAs a result of the inspection, it appears that Hunt has committed probable violations of the\nPipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The items\ninspected and the probable violations are as follows:\n1. §195.440 Public awareness.\n(a) Each pipeline operator must develop and implement a written continuing public\neducation program that follows the guidance provided in the American Petroleum\nInstitute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see\n§195.3).\nHunt did not provide information on emergency preparedness communications in its\nbaseline messages to Emergency Officials or Public Officials in accordance with\nAPI 1162, Table 2-1 Summary Public Awareness Communications for Hazardous Liquids\nand Natural Gas Transmission Pipeline Operators. The letter and brochure Hunt\nprovided to Emergency Responders and Public Officials instructs them to, “From a safe\nlocation, call 9-1-1 or local EMS and the pipeline company, giving your name, phone\nnumber, leak description and location.” While this message may be appropriate for the\nAffected Public, it is not appropriate for Emergency Officials and Public Officials\npossibly responding to a pipeline incident.\n\n\n\n2. §195.440 Public awareness.\n(a) Each pipeline operator must develop and implement a written continuing public\neducation program that follows the guidance provided in the American Petroleum\nInstitute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see\n§195.3).\nHunt did not provide baseline messages in 2008 to all of its Affected Public audience in\naccordance with API 1162, Table 2-1 Summary Public Awareness Communications for\nHazardous Liquids and Natural Gas Transmission Pipeline Operators. While the\nbrochure for the Affected Public was mailed to the Affected Public audience in\nMississippi in 2008, it was not mailed to Affected Public audience in Alabama.\n3. §195.440 Public awareness.\n… (d) The operator's program must specifically include provisions to educate the\npublic, appropriate government organizations, and persons engaged in excavation\nrelated activities on:\n… (2) Possible hazards associated with unintended releases from a hazardous liquid\nor carbon dioxide pipeline facility;\nHunt did not provide information in its baseline message to the Affected Public on the\npossible hazards associated with an unintended release of product from its hazardous\nliquid pipeline facility. That is, the brochure Hunt sent to the Affected Public did not\ncontain any information on the hazards associated with an unintended release from the\nHunt hazardous liquid pipeline.\n4. §195.440 Public awareness.\n… (i) The operator's program documentation and evaluation results must be\navailable for periodic review by appropriate regulatory agencies.\nHunt did not have adequate documentation to demonstrate that the 2006 baseline message\nmaterial for the Affected Public was delivered in accordance with API 1162, Table 2-1\nSummary Public Awareness Communications for Hazardous Liquids and Natural Gas\nTransmission Pipeline Operators. In 2006, Hunt contracted with Paradigm to deliver the\nbaseline message to the Affected Public by mailing a brochure via the U.S Postal\nService. Hunt did not have records, such as postal records or mailing lists, to adequately\ndocument that the mailings were completed.\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\ncorrect the item identified in this letter. Failure to do so will result in Hunt Crude Oil\nSupply Company being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2012-5009W. 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\n3","truncated":false,"body_characters":5864}