|
The Quality Petroleum, Inc.-Hoffman, et al. abandoned oil production facility (EPA ID 09-E-1181) was referred to United States Environmental Protection Agency (EPA) on February 28, 2006 by the State of Louisiana to be considered for Oil Pollution Act (OPA) response actions. This facility is located in Caddo Pine Island Oil and Gas Field (Field ID: 2152), approximately 2.8 miles southwest of Vivian, in Section 004, Township 21 North, Range 16 West of Caddo Parish, Louisiana. The facility is accessed from the northwest by an access road that is off of Monterey School Road.
The facility serviced one production well, identified as Hoffman, et al. Well No. 001 (SN 179621). Louisiana Department of Natural Resources (LDNR) records list this well as orphaned.
One potential oil spill source area was identified on this site from the LDNR orphan inspection records. Source 1 consisted of three above ground storage tanks (AST) and one separator (S) located in an eroded, breached, earthen secondary containment area (CONT), which were associated with SN 179621 by LDNR. LDNR records indicate SN 179621 is located at Latitude 32.842060 North and Longitude 94.028816 West. One pit (PIT) was identified as part of the same production lease by LDNR.
The facility was visited on November 15, 2006 and a site reconnaissance was conducted at that time. LDNR Conservation Enforcement Specialist (CES), Gerald Humphery, provided access to conduct on-site activities. During the reconnaissance, the general condition of the facility and containers was evaluated to determine the volume of oil and oil emulsion present, and a preliminary assessment of substantial threat to navigable waters of the United States was documented using revised EPA Region 6 protocols.
Determination of Threat
LDNR records indicate that the contents of the surface components consist of non-hazardous oilfield waste (NOW) in the form of oil, oil-emulsion, and/or oily produced water. These fluids meet the definition of "oil" as defined by Section 1001(23) of OPA, 33 U.S.C § 2701(23). The surface components were not gauged during the reconnaissance, but their volumes were estimated by the FOSC from acoustic and thermal differential observations.
Drainage from the facility flows southeast into an unnamed tributary of Caddo Lake that is part of the National Hydrology Dataset (NHD). The tributary of Caddo Lake is contiguous with, hydrologically connected to, and a primary tributary of Caddo Lake. Caddo Lake is navigable “in fact” and subject to interstate commerce (See. Drainage Map). The Caddo Lake – Jeems Bayou raw surface water intake is located approximately 5.6 miles downstream of the facility. (See. site drainage map, included in the site reconnaissance file [SRF], attached at the website for this facility).
The condition of all the containers at Source 1 was deemed to be inadequate. The area surrounding the containers was significantly overgrown with vegetation, indicating a lack of maintenance. Significant corrosion was present on the containers and connected flow lines. Oil and oil-saturated soil around containers indicated prior discharges to the environment and some tanks may be actively discharging their oily contents through seeps from delaminated metal at their bases and on connected flow lines. The secondary containment was eroded, breached, and did not appear to be adequate to prevent oil releases from draining to adjacent waterways. The availability capacity will need to be determined.
The FOSC has determined that a failure of the storage and process components through corrosion, vandalism or force majeure has a high potential to release a harmful quantity of oil within the meaning of Section 311 (b)(3) of the CWA, 33 U.S.C. § 1321(b)(3), and 40 CFR § 110.3(b), into the site drainage and ultimately into Caddo Lake.
The EPA Region 6 FOSC has determined from his reconnaissance that Source 1 of this facility meets the revised Region 6 substantial threat criteria.
Site Assessment (SA) activities will be conducted to obtain legally defensible field data that objectively quantifies and verifies the findings of substantial threat by the FOSC. If the SA sufficiently quantifies and verifies the findings of substantial threat by the FOSC, enforcement/administrative support will be necessary to build the administrative record and a cost recovery case for the site. These actions will be consistent with the criteria found in the U.S.C.G. NPFC Users Guide, July 2002.
POLREP No. 2 will outline results of the SA and advise of the EPA FOSC intentions for this abandoned facility.
If necessary, a Removal Project Plan (RPP) will be submitted to detail the planned corrective actions to address the substantial threat of discharge of oil to the navigable waters of the U.S., as defined in Section 311(a)(2) of Federal Waters Pollution Control Act (FWPCA), U.S.C. § 1321, 40 CFR Part 110.1 and Section 1001(7) of OPA, 33 U.S.C. § 2701(7), and 33 CFR 154.120, that is posed by this facility, as determined by the standard EPA threat analysis protocols, which are consistent with the criteria for determination of a substantial threat of discharge found in the U.S.C.G. NPFC Users Guide, July 2002.
Enforcement
All previous enforcement efforts by LDNR have produced no timely or technically appropriate responsible party actions, as evident by the current conditions at the facility. The well previously identified in this report as associated with this facility, the Hoffman, et al. Well No. 001 (SN 179621), was reported by LDNR as last operated by Quality Petroleum, Inc.- (Operator code Q008). LDNR records indicate these wells have been orphaned.
A deed and title search may be ordered to identify potential responsible parties (PRPs).
All of the attachments are available on the epaosc.net website as uploaded documents. Click on the hyperlink below to access the facility website to view the documents and photographs (images).
|
