FEDERAL REMOVAL RESPONSE ACTIVITIES COMMENCE WITH EFFORTS TO MITIGATE THE EFFECTS OF A DISCHARGE OF CRUDE OIL FROM AN ABANDONED (ORPHAN) OIL WELL LOCATED ON AN ABANDONED ON-SHORE PRODUCTION FACILITY KNOWN AS THE IRONS FARM AND TO ELIMINATE THE SUBSTANTIAL THREAT OF DISCHARGE OF CRUDE OIL FROM ENTERING INTO AN UNNAMED TRIBUTARY TO BAKERS RUN (NAVIGABLE WATERS OF THE UNITED STATES). BAKERS RUN IS A TRIBUARY TO SOUTH BRANCH KNAPP CREEK; WHICH IS A TRIBUTARY OF KNAPP CREEK, WHICH IS A TRIBUTARY TO THE ALLEGHENY RIVER.
IN APRIL 2016, THE LANDOWNERS REPORTED A DISCHARGE OF CRUDE OIL TO THE SURFACE OF THEIR PROPERTY FROM AN UNKNOWN, SUBSURFACE SOURCE TO THE COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION (“PADEP”) EMERGENCY RESPONSE PROGRAM (“ERP”). PADEP-ERP AND PADEP OIL & GAS MANAGEMENT PROGRAM (“OGMP”) RESPONDED AND OBSERVED A COATING OF OIL PRESENT ON THE YARD (APPROX 2’ RADIUS) AND ON SOME FLOWERS LOCATED NEAR A SIDEWALK ON THE PROPERTY. LOCAL RUMOUR INDICATED THERE WAS A PLUGGED OIL WELL NEAR THIS AREA, HOWEVER, PADEP COULD NOT DETERMINE THE EXACT LOCATION. PADEP CONCLUDED AN ABANDONED (~6” DIAMETER) OIL LINE WAS BURIED ON THE PROPERTY, WHICH APPARENTLY RUNS THROUGH THE AREA WHERE THE OIL HAS REACHED THE SURFACE AND WOULD BE THE LIKELY SOURCE OF THE ISSUE. AS THERE WAS NOT AN ONGOING DISCHARGE AT THE TIME OF PADEP’S INVESTIGATION, THEREFORE, THE PROPERTY OWNER WAS ASKED TO CONTACT PADEP IF AN APPRECIABLE AMOUNT OF ADDITIONAL OIL SURFACES. IF THIS IS A RECURRING ISSUE, PADEP INDICATED IT WOULD INSPECT THE ABANDONED OIL LINE FARTHER AWAY FROM THE INCIDENT SITE AND ATTEMPT TO FIND A RESPONSIBLE PARTY FOR THE ABANDONED OIL LINE.
IN OCTOBER 2016, THE LANDOWNERS REPORTED A DISCHARGE OF CRUDE OIL TO THE SURFACE OF THEIR PROPERTY FROM AN UNKNOWN, SUBSURFACE SOURCE. LOCAL FIRE HAZMAT RESPONDED TO THE SCENE, OBSERVED THE SURFACE AREA AFFECTED BY THE DISCHARGE AND WERE ABLE TO UNCOVER THE BURIED WELL. LOCAL FIRE HAZMAT INITIATED DEFENSIVE ACTIONS WHICH EFFECTIVELY PREVENTED THE DISCHARGE OF CRUDE OIL FROM ENTERING INTO THE UNNAMED TRIBUTARY TO BAKERS RUN (NAVIGABLE WATERS OF THE UNITED STATES). PADEP-OGMP FOLLOWED-UP, CONFIRMED THE SOURCE TO BE AN ABANDONED (ORPHAN) WELL, BUT INFORMED THE LANDOWNER THAT PADEP DID NOT HAVE THE RESOURCES TO CONDUCT A REMOVAL ACTION (INCLUDING BUT NOT NECESSARILY LIMITED TO PLUGGING THE WELL)
ON OCTOBER 30, 2016, THE LANDOWNER REPORTED THE INCIDENT TO THE NATIONAL RESPONSE CENTER (“NRC”). NRC #1162898 WAS ASSIGNED TO THE CASE. IN FOLLOW-UP TO RECEIPT OF NRC #1162898, EPAR3 DUTY OFFICER, OSC MYLES BARTOS, NOTIFIED OSC VINCENT ZENONE, THE LEAD OSC FOR THE NW PA SUB-AREA OF THE EPAR3 INLAND AREA CONTINGENCY PLAN, AND HENCEFORTH REFERRED TO AS “THE OSC”. BECAUSE NRC #1162898 INDICATES THE INCIDENT HAS BEEN GOING ON FOR A WHILE, THE OSC FOLLOWED-UP WITH THE PADEP-ERP AT PADEP’S NORTHWEST REGIONAL OFFICE REQUESTING INFORMATION REGARDING ANY PRIOR COMPLAINTS AND PADEP’S PLANS TO FOLLOW-UP TO NRC #1162898. THE OSC ALSO PROVIDED PADEP-ERP THE CORRECT LOCATION OF THE INCIDENT AS 23 BAKERS TRESTLE ROAD, RIXFORD, PA 16745 (NOT 23 BAKERS TRUSSEL ROAD).
ON OCTOBER 31, 2016, VIA RETURN EMAIL, PADEP-ERP PROVIDED SOME ADDITIONAL INFORMATION TO THE OSC REGARDING PADEP’S FOLLOW-UP TO THE LANDOWNER’S COMPLAINT IN APRIL 2016.
ON NOVEMBER 1, 2016, VIA TELECOMS, THE OSC CONTINUED FOLLOW-UP NRC #1162898 AND DISCUSSED THE INCIDENT WITH THE REPORTING PARTY, WHO IS ALSO THE PERSON WHO OWNS THE SURFACE UPON WHICH THE ABANDONED ORPHAN WELL WAS SITUATED. THE OSC ATTAINED VERBAL CONSENT FROM THE LANDOWNER TO ACCESS THE PROPERTY, ASSESS THE SOURCE, EVALUATE THE SUBSTANTIAL THREAT OF DISCHARGE TO THE NAVIGABLE WATERS OF THE U.S. (BAKERS RUN, IT’S TRIBUTARIES AND/OR ADJOINING SHORELINES), INITIATE DEFENSIVE ACTIONS AND ARRANGE FOR A TIMELY FEDERAL REMOVAL ACTION AS MAY BE APPLICABLE.
ON NOVEMBER 8, 2016, THE OSC CONTINUED FOLLOWING-UP NRC #1162898 WITH AN ON-SITE PRELIMINARY ASSESSMENT / REMOVAL EVALUATION. BASED UPON VISUAL OBSERVATIONS OF THE ABANDONED LEAKING OIL WELL, IN CONJUNCTION WITH THE OSC’S PAST, PERTINENT KNOWLEDGE OF THE PENNSYLVANIA GRADE CRUDE OIL PRODUCING AREA OF NORTHWESTERN, THE OSC PRESUMED THAT THE OIL PRODUCTION FACILITY MAY HAVE BEEN ABANDONED SOMETIME AROUND THE MIDDLE OF THE 20TH CENTURY (MID-1900'S). THE OSC’S PRESUMPTION WAS SUPPLIMENTED WITH INFORMATION PROVIDED BY THE LANDOWNER THAT THE PRODUCER (THE PERSON WHO OWNED/OPERATED THE FACILITY IMMEDIATELY PRIOR TO ABANDONMENT) HAD ARRANGED TO HAVE ANOTHER LEAKING WELL ON THE PROPERTY PLUGGED IN THE EARLY 1980’S. BASED UPON REVIEW OF DOCUMENTATION AND INFORMATION GATHERED DURING AND SUBSEQUENT TO THE WELL-SITE-SPECIFIC RECONNAISSANCE, THE OSC DETERMINED THAT THE ABANDONED/ORPHAN WELL WAS PART OF THE IRONS FARM LAST OWNED/OPERATED BY ROBERT E. HUNGIVILLE, JR (DECEASED). THE OSC DETERMINED THAT THE WELL ASSESSED THIS DATE POSED A SUBSTANTIAL THREAT TO DISCHARGE CRUDE OIL INTO OR UPON THE NAVIGABLE WATERS OF THE UNITED STATES AND/OR ITS TRIBUTARIES AND SHORELINES. THE OSC’S WELL-SITE-SPECIFIC REMOVAL EVALUATION AND DETERMINATIONS ARE AS FOLLOWS:
IRONS FARM WELL: DESIGNATION OF SOURCE AND DETERMINATION OF THREAT: BASED UPON REVIEW OF OLD LEASE MAPS AND OTHER RECORDS, THE ORPHAN WELL APPEARS TO BE PART OF AN ABANDONED ON-SHORE PRODUCTION FACILITY KNOW AS THE IRONS FARM. REVIEW OF OLD LEASE MAPS DEPICT A WELL DESIGNATED AS PLUGGED, WHICH POSSIBLY COULD BE THIS WELL, HOWEVER, WELLS PLUGGED PRIOR TO CURRENT PADEP-OGMP REQUIREMENTS TYPICALLY WERE ONLY BRIDGED-OFF ABOVE THE PRODUCTION SANDS, LEAVING AN OPEN HOLE TO THE SURFACE, WITH THE BOREHOLE IN COMMUNICATION WITH OTHER OIL-BEARING FORMATIONS. WELLS PLUGGED PRIOR TO CURRENT REQUIRMENTS, TEND TO LOSE EFFECTIVENESS OVER TIME, EVENTUALLY DISCHARGING FLUIDS TO GROUNDWATER AND/OR SURFACE WATERS. THE SURFACE EQUIPMENT (JACK, OIL AND GAS LINES) WERE NOT PRESENT. IN APRIL 2016, THE LANDOWNERS HAD REPORTED A DISCHARGE OF CRUDE OIL TO THE SURFACE OF THEIR PROPERTY FROM AN UNKNOWN, SUBSURFACE SOURCE TO PADEP. PADEP RESPONDED, OBSERVED AN APPROX 2-FOOT DIAMETER RADIUS OF OIL CONTAMINATION, BUT DID NOT LOCATE THE SOURCE AND CLOSED THE CASE. IN OCTOBER 2016, LOCAL FIRE HAZMAT RESPONDED TO THE SCENE, OBSERVED THE DISCHARGE AND WERE ABLE TO UNCOVER THE BURIED WELL. LOCAL FIRE HAZMAT INITIATED DEFENSIVE ACTIONS WHICH PREVENTED THE DISCHARGE OF CRUDE OIL FROM ENTERING INTO AN UNNAMED TRIBUTARY TO BAKERS RUN (NAVIGABLE WATERS OF THE UNITED STATES). DURING TODAY’S REMOVAL ASSESSMENT, PRODUCTION FLUIDS COULD BE OBSERVED APPROX 8 - 10 FEET DOWNHOLE. DRAINAGE FROM THE IRONS FARM WELL FLOWS OVERLAND, DOWNGRADIENT APPROX 75 FEET TO A CULVERT WHICH RUNS BENEATH BAKERS RUN ROAD. DRAINAGE CONTINUES THROUGH THE CULVERT INTO A CLEARLY DEFINED STREAM CHANNEL (UNNAMED INTERMITTENT TRIBUTARY), CONTINUING APPROX 120 FEET INTO A WETLAND AREA AND INTO AN UNNAMED TRIBUTARY. THE UNNAMED TRIBUTARY FLOWS APPROX 450 FEET TO ITS CONFLUENCE WITH BAKERS RUN. BAKER RUN IS A TRIBUARY TO SOUTH BRANCH KNAPP CREEK; WHICH IS A TRIBUTARY OF KNAPP CREEK, WHICH IS A TRIBUTARY TO THE ALLEGHENY RIVER. THE OSC DETERMINED THAT THE IRONS FARM WELL POSED A SUBSTANTIAL THREAT TO DISCHARGE CRUDE OIL INTO THE NAVIGABLE WATERS OF THE UNITED STATES. THIS DETERMINATION WAS BASED UPON THE OSC’S OBSERVATIONS AND CONSIDERATION OF THE GEOGRAPHICAL, LOCATIONAL ASPECTS OF THE WELL; DRAINAGE PATTERNS, LAND CONTOURS AND DISTANCE FROM THE WELL TO PERENNIAL OR INTERMITTENT STREAMS, PONDS, DITCHES, WETLANDS, OR OTHER NAVIGABLE WATERS; THE POTENTIAL VOLUME OF CRUDE OIL WHICH COULD BE DISCHARGED FROM THE WELL; IN CONJUNCTION WITH WORSE CASE WEATHER CONDITIONS WHICH COULD EXACERBATE A DISCHARGE OF CRUDE OIL FROM THE WELL, AND THE CONDITION OF THE ORPHAN WELL (ABANDONED AND UNMAINTAINED).
ON NOVEMBER 9, 2016, THE OSC MET WITH PADEP-OGMP OIL & GAS INSPECTOR (“OGI”) TIM CURRY AT THE MCKEAN COUNTY COURTHOUSE IN SMETHPORT, PA. PADEP-OGI CURRY CONFIRMED PADEP-OGMP DID NOT HAVE THE RESOURCES TO CONDUCT THE NECESSARY REMOVAL ACTION, THEREFORE, THE OSC ADVISED PADEP-OGMP THAT IN ABSENCE OF A VIABLE RESPONSIBLE PARTY (“RP”), EPAR3 WOULD ASSUMED LEAD AGENCY RESPONSIBILITIES. PADEP-OGMP OFFERED TO PROVIDE WHATEVER ASSISTANCE IT COULD MUSTER IN SUPPORT OF THE LEAD AGENCY’S EFFORTS. THE OSC REQUESTED PADEP-OGMP CHECK ITS RECORDS FOR A COPIES OF THE NOTICE OF INTENT TO PLUG WELL AND/OR THE WELL PLUGGING CERTIFICIATE WHICH SHOULD HAVE BEEN SUBMITTED BY THE OWNER / OPERATOR OF ANTHER WELL ON THE PROPERTY WHICH HAD BEEN RECENTLY (1980’S) PLUGGED, AS SUCH DOCUMENTS WOULD PROVIDE ADDITIONAL CONFIRMATION OF THE IDENTITY OF THE RP AND PROVIDE SOME DOWNHOLE INFORMATION WHICH COULD BE VALUABLE IN THE PREPARATIONS TO PLUG THE WELL SUBJECT TO THIS FEDERAL REMOVAL RESPONSE ACTION.
ON NOVEMBER 14, 2016, THE OSC MET WITH PADEP-OGI TIM CURRY AT THE EPA COMMAND POST IN BRADFORD, PA TO DISCUSS RESULTS OF PRP-SEARCH TO DATE. THE OSC ADVISED PADEP-OGMP THAT THE OSC’S PRP-SEARCH, SOURCE DESIGNATION AND RP IDENTIFICATION NEARS ITS CONCLUSION, AND REQUESTED PADEP-OGMP TO CONTINUE EFFORTS TO
[A] LOCATE A COPY OF THE WELL PLUGGING CERTIFICATE;
[B] CONFIRM IF THE WELLS ON THE IRONS FARM WERE EVER REGISTERED;
[C] CONFIRM IF THE WELLS ON THE IRONS FARM WERE EVER TRANSFERRED TO ANOTHER PARTY; AND
[D] PROVIDE AN API NUMBER FOR THE WELL IF IT HAD NOT BEEN REGISTERED OR TRANSFERRED TO ANOTHER PARTY.
ON NOVEMBER 30, 2016, OSC ZENONE ACCESSED THE OSLTF VIA CANAPS AND OBTAINED AN INITIAL PROJECT CEILING OF $50,000 AND FPN E16314 WAS ASSIGNED TO THE CASE TO COMMENCE REMOVAL RESPONSE ACTIVITIES INCLUDING BUT NOT NECESSARILY LIMITED TO CONTINUE MAINTAINING DEFENSIVE ACTIONS, SECURING THE SITE, EFFORTS TO THE EXTENT PRACTICABLE TO IDENTIFY POTENTIALLY RESPONSIBLE PARTIES (“PRPS”), IDENTIFY THE RESPONSIBLE PARTY (“RPS”), AFFORD THE RP AN OPPORTUNITY TO VOLUNTARILY AND PROMPTLY PERFORM REMOVAL ACTIONS, AND/OR IN ABSENCE OF A VIABLE RP, UNDERTAKE THE REMOVAL ACTIONS NECESSARY TO MITIGATE THE EFFECTS OF THE DISCHARGE AND THE SUBSTANTIAL THREAT OF DISCHARGE OF CRUDE OIL INTO BAKERS RUN, ITS TRIBUTARIES AND ADJOINING SHORELINES.
