Site Location
The Thor Max Operating, Inc.-Grey-Hickey abandoned oil production facility (EPA ID 09-E-1150) was referred to the 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 miles northwest of Greenwood, in Section 030, Township 18 North, Range 16 West (Sec. 030, T18N, R16W) of Caddo Parish, Louisiana. The facility is accessed from the north via unnamed oil field roads that are off of Masters Road.
Site Description
The facility consists of two above ground storage tanks (AST), one heater treater (HT), one secondary containment area (CONT), and ten production wells located at one potential spill source (Source 1).
The facility serviced ten production wells, identified as the Grey-Hickey Well No. 001, (SN 172651); Grey-Hickey Well No. 002, (SN 173137); Grey-Hickey Well No. 003, (SN 173206); Grey-Hickey Well No. 004, (SN 173207); Grey-Hickey Well No. 005, (SN 173318); Grey-Hickey Well No. 006, (SN 173319); Grey-Hickey Well No. 007, (SN 175392); Grey-Hickey Well No. 008, (SN 175393); Grey-Hickey Well No. 009, (SN 175394); and Grey-Hickey Well No. 010, (SN 175395). The Louisiana Department of Natural Resources (LDNR) records list all of these wells as orphaned.
Source 1 consists of two bolted-steel tanks, identified as AST1 and AST2, and a welded-steel heater treater, identified as HT1, located in a roughly-rectangular 105-foot by 52-foot breached and eroded, earthen-bermed, secondary containment area identified as CONT1.
Based on gauging, thermal and acoustic differentials, and surface soil, core, and field observations, the following volumes of non-hazardous oilfield waste (NOW) were estimated to be present at Source 1 of the facility. AST1 and AST2 contain a total of 121.5 barrels (bbl) of oil and oil emulsion. HT1 is estimated to contain an additional 11.2 bbl of oil emulsion based on thermal imaging and acoustic differentials. The contents of these containers were documented as NOW. In addition, CONT 1 has 1.9 bbl of pooled oil and 38.4 cubic yards (yd3) of oil-saturated/heavily oil-stained soil.
Previous Actions
The EPA Region 6 Federal On-Scene Coordinator (FOSC) conducted a reconnaissance of the facility on October 26, 2007 to determine if this facility meets the revised Region 6 substantial threat criteria. The FOSC has determined from his reconnaissance that Source 1 of this facility meets the criteria for proceeding with a Site Assessment (SA) (See. Minimum Threshold Checklist attached at the website for this facility).
On April 2, 2008, the SA was conducted by the United States Army Corps of Engineers (USACE) and their contractor, on behalf of the EPA, to document the condition of the abandoned facility. Access to conduct on-site activities was coordinated with LDNR Conservation Enforcement Specialist (CES), Don Owens.
AST1 and AST2 were gauged and their conditions were documented. Due to the lack of access ports or potentially pressurized conditions, HT1 could not be accessed for gauging, but the volume of its contents was determined by thermal imaging and acoustic differentials and its condition was documented. Containers AST1, AST2 and HT1 were actively discharging their oily contents through seeps in corroded and delaminated metal at their bases. Oil and oil-saturated soil around container AST2 indicated prior discharges to the environment. All containers at Source 1 had heavy corrosion at the lower tank sidewalls and on connecting flow lines.
The surface condition of CONT1 was documented. The local elevations were surveyed to determine the capacity of each containment area and the slope to the nearest drainage. Observation soil cores were also used to determine the extent of the oil saturation of the soil below ground surface (BGS).
Oily liquid seeping through delaminated metal at the base of AST1 and AST2 created areas of pooled oil and oil-saturated soil in the northern third of CONT1. Soil cores revealed that oil-saturated soil extended to a maximum depth of 1.7 feet BGS. A breach eroded through the eastern earthen berm of CONT1 significantly reduced the containment capacity and allowed it to drain through wetlands to adjacent waterways.
The area surrounding CONT1 is heavily vegetated and wooded. Medium-sized trees were growing next to the tanks in CONT1. The northern half on CONT1 is elevated one foot above the southern half, and there are shallow depressions in both areas which keep the oil and water pooled around AST1 and AST2. Lack of maintenance was evident in CONT1 from the oil-saturated soil, the eroding and breached berms, and the heavily overgrown conditions.
The wellheads for SN 172651, SN 173206, SN 173207, SN 175392, SN 175393, SN 175394, and SN 175395 were located and their condition was documented. The wellheads and the connected flow lines, where present, were heavily corroded. Open well casings were noted on SN 175394 and SN 173206. The SN 173137, SN 173318, and SN 173319 wellheads were not located during the assessment.
Determination of Threat
Drainage from Source 1 discharges into and flows south down gradient (a 10-foot drop over 250 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 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 attached at the website for this facility).
Based on the SA data, there are approximately 134.6 bbl of oil and oil emulsion that meet the definition of "oil" as defined by Section 1001(23) of OPA, 33 United States Code (U.S.C.) § 2701(23).
An actual and substantial threat of discharge was determined to exist by the FOSC at Source 1. Containers AST1, AST2 and HT1 were actively discharging their oily contents through seeps from corroded and delaminated metal at their bases. All containers at Source 1 have heavy corrosion at the lower tank sidewalls and on connecting flow lines. Due to their poor condition, catastrophic failure is imminent; meaning all tank contents will be released directly into a GAP defined wetland. The berm of the secondary containment around containers AST1, AST2 and HT1 is breeched, reducing its holding capacity. As a result, 134.6 barrels (bbl) of oil and oil emulsion could drain from Source 1 and flow downgradient, through the aforementioned GAP defined wetland, ultimately impacting Cross Lake and the Red River if action is not taken to mitigate this threat.
The FOSC has determined that the ongoing discharge (seeps) and/or 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 (CWA), 33 U.S.C. § 1321(b)(3), and 40 Code of Federal Regulations (CFR) § 110.3(b), into the site drainage and ultimately into Cross Lake and the Red River.
The SA and Enforcement Summary reports contain legally defensible field data that objectively quantifies and verifies the findings of substantial threat by the FOSC, and the enforcement/administrative support necessary to build the administrative record and a cost recovery case for the site. These actions are consistent with the criteria found in the U.S.C.G. National Pollution Fund Center (NPFC) Users Guide, July 2002.
POLREP No. 3 will advise of any potential responsible party (PRP) response or actions in response to the Notice of Federal Interest (NOFI), and 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
The last Operator of Record/ PRP has been identified through the file maintained by the LDNR, Office of Conservation as Thor Max Operating, Inc. (Operator Code T133). The wells identified in the assessment report as being associated with this facility, specifically the: Grey-Hickey Well No. 001, (SN 172651); Grey-Hickey Well No. 002, (SN 173137); Grey-Hickey Well No. 003, (SN 173206); Grey-Hickey Well No. 004, (SN 173207); Grey-Hickey Well No. 005, (SN 173318); Grey-Hickey Well No. 006, (SN 173319); Grey-Hickey Well No. 007, (SN 175392); Grey-Hickey Well No. 008, (SN 175393); Grey-Hickey Well No. 009, (SN 175394); and Grey-Hickey Well No. 010, (SN 175395), were reported by LDNR as last operated by this operator. LDNR records indicate these wells have been orphaned. 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.
A deed and title search was conducted to identify any other PRPs. All identified PRPs will be sent a NOFI.
The EPA FOSC has formally offered the PRPs the opportunity to conduct the necessary mitigation actions to abate any potential sources of release at the site through issuance of a NOFI. If the PRP declines to participate, or fails to initiate a timely respond to notice, EPA plans to proceed with an Oil Spill Liability Trust Fund (OSLTF) financed cleanup action. The NOFI will clearly advise the PRP they may be subsequently held liable for the cost of government funded cleanup actions.
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