# HUNT CRUDE OIL SUPPLY CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 220125010M
- **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:** 2012-07-25
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.440(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220125010m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220125010m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220125010m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220125010M
**body:**

Notice of Amendment involving HUNT CRUDE OIL SUPPLY CO. PHMSA's enforcement data identifies the cited regulation as 195.440(a). The case was opened on 2012-07-25 and is reported as closed as of 2012-11-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220125010M_closure letter_11192012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125010M/220125010M_closure%20letter_11192012.pdf

220125010M_closure letter_11192012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125010M/220125010M_closure%20letter_11192012_text.pdf

220125010M_notice of amendment_07252012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125010M/220125010M_notice%20of%20amendment_07252012.pdf

220125010M_notice of amendment_07252012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125010M/220125010M_notice%20of%20amendment_07252012_text.pdf

220125010M_notice of amendment_07252012_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 25, 2012
Mr. Joe Giglotto
Senior Vice President Operations
Hunt Crude Oil Supply Company
2200 Jack Warner Pkwy., Suite 400
Tuscaloosa, AL 35401
CPF 2-2012-5010M
Dear Mr. Giglotto:
From June 4-5, 2012, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) inspected the Hunt Crude Oil Supply Company (Hunt) written
Public Awareness Program at your Tuscaloosa, AL refinery office pursuant to Chapter 601 of
49 United States Code.
On the basis of the inspection, PHMSA has identified apparent inadequacies within Hunt’s
written Public Awareness Program procedures, as described below:
1. §195.440 Public awareness.
(a) Each pipeline operator must develop and implement a written continuing public
education program that follows the guidance provided in the American Petroleum
Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see
§195.3).
Hunt’s written Public Awareness Program (PAP) procedures listed “Newspaper Ads” as
a baseline message material. American Petroleum Institute Recommended Practice 1162
(API RP 1162), Table 2-1 Summary Public Awareness Communications for Hazardous
Liquids and Natural Gas Transmission Pipeline Operators states an acceptable method
of message delivery is “Targeted distribution of print materials.”
While newspaper ads are printed materials, they are not targeted to a specific stakeholder
audience. Also, there is no way for an operator to assure or measure receipt of newspaper
ads by a given stakeholder audience. PAP baseline messages need to be distributed in a
manner that assures the material is received by the intended audience.



2. §195.440 Public awareness.
(a) Each pipeline operator must develop and implement a written continuing public
education program that follows the guidance provided in the American Petroleum
Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see
§195.3).
Hunt’s written PAP procedures did not provide for conducting a program effectiveness
evaluation for all stakeholder audiences. API RP 1162; Section 8.4 Measuring Program
Effectiveness requires a program effectiveness evaluation be conducted for all
stakeholder audiences.
The Hunt PAP procedures addressed conducting a program effectiveness evaluation for
the Affected Public but did not address Emergency Officials, Public Officials and
Excavators.
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.
It is requested (not mandated) that Hunt Crude Oil Supply Company 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 T. Lemoi, Director,
Southern Region, Pipeline and Hazardous Materials Safety Administration. In
2



correspondence concerning this matter, please refer to CPF 2-2012- 5010M 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

220125010M_closure letter_11192012_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 19, 2012
Mr. Joe Giglotto
Senior Vice President Operations
Hunt Crude Oil Supply Company
2200 Jack Warner Pkwy., Suite 400
Tuscaloosa, AL 35401
CPF 2-2012-5010M
Dear Mr. Giglotto:
From June 4-5, 2012, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Southern Region, Office of Pipeline Safety inspected the Hunt
Crude Oil Supply Company (Hunt) written Public Awareness Program at your Tuscaloosa,
Alabama, refinery office pursuant to Chapter 601 of 49 United States Code. As a result of the
inspection, PHMSA issued a Notice of Amendment (NOA) on July 25, 2012.
On September 6, 2012, Hunt sent an email to the Southern Region requesting a time extension
to respond to the NOA. I granted an extension until October 31, 2012, via return email on the
same day.
The PHMSA Southern Region received your written response to the NOA dated October 5,
2012. We reviewed the response and find that Hunt’s amended procedures are adequate.
This letter is to inform you that Hunt has complied with the terms of the NOA and that no
further actions are necessary with regards to the NOA. This case is now closed.
Please be advised that this letter refers only to the NOA (CPF 2-2012-5010M) and not to any
other PHMSA pending cases, if any. Also be advised that nothing herein states or implies
that the Hunt Public Awareness Program meets the requirements of the federal pipeline safety
regulations or that the Public Awareness Program is approved. The pipeline system and
Public Awareness Program remain subject to inspection by PHMSA.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
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