Site Location
The Thor Max Operating, Inc.-Grey-Hickey abandoned oil production facility (EPA ID 09-E-1150) was referred to United States Environmental Protection Agency (EPA) on September 1, 2007 by the State of Louisiana to be considered for Oil Pollution Act (OPA) response actions. This facility is located in the Longwood Oil and Gas Field (Field ID: 6220), approximately 6.4 mile northwest of Greenwood, in Section 030, Township 18 North, Range 16 West of Caddo Parish, Louisiana. The facility is accessed from the north via unnamed oil-field roads that are off of Blanchard-Furrh Road.
Site Description
The facility serviced ten production wells, identified as the: Gray-Hickey Well No. 001, (SN 172651); Gray-Hickey Well No. 002, (SN 173137); Gray-Hickey Well No. 003, (SN 173206); Gray-Hickey Well No. 004, (SN 173207); Gray-Hickey Well No. 005, (SN 173318); Gray-Hickey Well No. 006, (SN 173319); Gray-Hickey Well No. 007, (SN 175392); Gray-Hickey Well No. 008, (SN 175393); Gray-Hickey Well No. 009, (SN 175394); and Gray-Hickey Well No. 010, (SN 175395). The Louisiana Department of Natural Resources (LDNR) records list all of these wells as orphaned.
One potential oil spill source area was identified on this site from the LDNR orphan inspection records. Source 1 consists of three above ground storage tanks (AST), one heater treater (HT), and one secondary containment area (CONT), which were associated with SN 172651 by LDNR. LDNR records indicate SN 172651 is located at Latitude 32.522587 North and Longitude - 94.038917 West. One pit (PIT) was identified as part of the same production lease by LDNR.
The facility was visited on October 26, 2007, and a site reconnaissance was conducted at that time. LDNR Conservation Enforcement Specialist (CES), Don Owens, 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 Source 1 discharges into and flows south down gradient (a 15-foot drop over 150 feet) through a Gap Analysis Program (GAP) defined wetland to a National Hydrography Dataset (NHD) defined perennial tributary of the Cross Lake, both of which are hydrologically connected to and form a significant surface water nexus with the Cross Lake. Cross Lake is hydrologically connected to and forms a significant surface water nexus with the Red River. The Red River is navigable “in fact” and subject to interstate commerce. (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. Significant corrosion was present on the containers and connected flow lines. Oil and oil-saturated soil around containers indicated prior discharges to the environment. The tanks were actively discharging their oily contents through seeps from delaminated metal at their bases. The secondary containment, where present, 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 Clean Water Act, 33 U.S.C. § 1321(b)(3), and 40 CFR § 110.3(b), into the site drainage and ultimately into Cross Lake and the Red River.
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 wells previously identified in this report as associated with this facility, specifically the: Gray-Hickey Well No. 001, (SN 172651); Gray-Hickey Well No. 002, (SN 173137); Gray-Hickey Well No. 003, (SN 173206); Gray-Hickey Well No. 004, (SN 173207); Gray-Hickey Well No. 005, (SN 173318); Gray-Hickey Well No. 006, (SN 173319); Gray-Hickey Well No. 007, (SN 175392); Gray-Hickey Well No. 008, (SN 175393); Gray-Hickey Well No. 009, (SN 175394); and Gray-Hickey Well No. 010, (SN 175395), were reported by LDNR as last operated by Thor Max Operating, Inc. (Operator code T133). 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).
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