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Site Location
The Quality Petroleum, Inc.-Hoffman, et al. abandoned oil production facility (EPA ID 09-E-1181) was referred to the 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 the 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 (Sec. 004, T21N, R16W) of Caddo Parish, Louisiana The facility is accessed from the northwest by an access road that is off of Monterey School Road.
Site Description
The facility consists of three above ground storage tanks (AST), one separator (S), one secondary containment area (CONT), and one production well located at one potential spill source (Source 1).
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.
Source 1 consists of two welded-steel ASTs, identified as AST1 and AST2, a fiberglass AST, identified as AST3, and one welded-steel gun-barrel type separator, identified as S1, located in a rectangular 70-foot by 30-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, AST2, and AST3 contain a total of 32.1 barrels (bbl) of oil and oil emulsion and 68.4 bbl of oily produced water. S1 is estimated to contain an additional 42.4 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 26.4 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 November 15, 2006 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 5, 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, AST2, and AST3 were gauged and their conditions were documented. Due to the lack of access ports, S1 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. Container AST1 was actively discharging its oily contents through seeps from corroded and delaminated metal at its base. Container AST3 was also actively discharging its oily contents through seeps from peeling and degraded fiberglass at its base. All containers at Source 1 had heavy corrosion at the lower tank sidewalls and/or 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 AST3 created areas of oil-saturated soil in most of CONT1. Soil cores revealed that oil-saturated soil extended to a maximum depth of 1 foot BGS. A breach eroded in southern earthen berm of CONT1 significantly reduced the containment capacity and allowed it to drain oily water to adjacent waterways. Water with an oily sheen was pooled up to a depth of 0.5 foot in the southern portion of CONT1. Medium pines and vegetation were present in CONT1. Lack of maintenance was evident from the heavily overgrown condition, eroding berms, and the oil-saturated soil in CONT1.
The wellhead for SN 179621 was located at the coordinates reported by LDNR and its condition was documented. The wellhead and the connected flow lines were heavily corroded.
Determination of Threat
Drainage from Source 1 flows southeast down gradient (a 35-foot drop over 770 feet) to a National Hydrography Dataset (NHD) defined perennial tributary of the Caddo Lake, which is hydrologically connected to and form a significant surface water nexus with the Caddo Lake. Caddo Lake 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 74.5 bbl of oil and oil emulsion, and 68.4 bbl of oily produced water 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 and AST3 were actively discharging their oily contents through seeps from corroded and delaminated metal or peeling and degraded fiberglass 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 into secondary containment, where present. The berm of the secondary containment around the containers is breeched, reducing its holding capacity. As a result, 74.5 bbl of oil and oil emulsion and 68.4 bbl of oily produced water could drain from Source 1 and flow downgradient, ultimately impacting the Caddo Lake 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 Caddo Lake.
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 LDNR, Office of Conservation as Quality Petroleum, Inc., (Operator Code Q008). The well identified in the assessment report as being associated with this facility, specifically the: Hoffman, et al. Well No. 001 (SN 179621) was reported by LDNR as last operated by this operator. LDNR records indicate this well has 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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