Pollution/Situation Report Profile

Winganon Oil Spill Project
Winganon, OK - EPA Region VI
POLREP #2
Progress of Re-Assessment

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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Winganon Oil Spill Project - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region VI

Subject:

POLREP #2
Progress of Re-Assessment
Winganon Oil Spill Project
V6KC
Winganon, OK
Latitude: 36.5797986 Longitude: -95.5333757

To:

From:

Roberto Bernier, FOSC

Date:

3/17/2010

Reporting Period:

12/15/2010 - 3/15/2010

1. Introduction

1.1 Background

Site Number:	V6KC	Contract Number:
D.O. Number:		Action Memo Date:
Response Authority:	OPA	Response Type:	Emergency
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:	12/14/2009	Start Date:
Demob Date:	9/30/2010	Completion Date:
CERCLIS ID:		RCRIS ID:
ERNS No.:		State Notification:
FPN#:	E10606	Reimbursable Account #:

1.1.1 Incident Category

Discharging or Threatening to Discharge Abandoned Oil Production Wells

1.1.2 Site Description

In early 2009, the Oklahoma Corporation Commission (OCC) requested EPA-R6 assistance with several abandoned oil production wells that were leaking crude oil in areas located near Lake Oologah and its tributaries. The wells were from leases that were initially part of Phase I of the Lake Oologah Oil Spill Project (Oologah Project) and that were not addressed then because they were either part of an active lease or were secured at the time. With no viable responsible party (RP) after many years from the original project phase, EPA proceeded to address the wells by Plugging and Abandonment (P&A). After noticing the large number of wells now discharging or threatening to discharge crude oil, EPA conducted a re-assessment of all the wells that were not P&A within the previous Phases of the Oologah Project. The re-assessments were to determine if the wells were now discharging or threatening to discharge into navigable waters of the U.S. and adjoining shorelines.

During the winter of 2009-2010, EPA conducted a re-assessment of all the wells within the Oologah Project database that were not P&A during previous phases and noticed that a substantial number of the wells were now discharging or threatening to discharge oil, unsecured, and potentially abandoned with no viable RP.

1.1.2.1 Location

The wells are located in the east side of Lake Oologah scattered within 21 Sections in Rogers and Nowata counties in Oklahoma. In specific, Sections 4, 5, 6, 8, 9, 16, 17, 20, 21, 28, 30, and 32 of Township (T) 24N, Range (R) 17E and Sections 23, 24, 25, and 26 of T 24N, R 16E, in Rogers County; and, Sections 16, 17, 28, 29, and 32 of T 25N, R 17E in Nowata County.

The Command Post for the project is located in Section 7 T 24N, R 17E, in specific 16510 A&B E 300 Road, Chelsea, Rogers Co., Oklahoma. The coordinates are Latitude 36.58018º N, Longitude 95.53283º W.

1.1.2.2 Description of Threat

The re-assessment revealed that most of the wells seemed to be abandoned and that equipment associated with production has been removed, leaving the wells unsecured and many of them substantially discharging oil onto the surrounding area. The wells that are not visually leaking are completely unsecured with crude oil measured inside the well within a close distance from the top of the casing. All the unsecure and/or leaking wells are located next or near to a ditch, ravine, or creek that drains directly to Lake Oologah within a short distance. Drainage throughout the project area is within 0-4 miles of and contiguous with the lake. Lake Oologah is a navigable waterway of the U.S. and a drinking water source for the city of Tulsa and other smaller municipalities in the area.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

Between November of 2009 and January of 2010, EPA conducted a comprehensive re-assessment of wells not P&A within Phases I, II, and III of the Oologah Project. After corroborating previous property access agreements, ground teams visited the sites using GPS coordinates already logged into the project database. The reassessment consisted of ground inspections of each site for visual observations, and determining the depth of fluids from the top of casing for those wells that a discharge was not apparent. Close to 2,500 well sites within 36 Sections were visited and a substantial number of the wells are now actively discharging or threatening to discharge crude oil, unsecured, and potentially abandoned with no viable RP. Of those, 228 wells were identified to require some type of removal action (plugging or repairs). Based on observations and discussion with current owners and/or operators still producing oil in the area, about one half of those wells can be addressed by RPs. The rest appear to be abandoned with almost no possibility that a viable potential RP (PRP) could be found.

2. Current Activities

After determining the number of wells that needed some type of a removal action, EPA conducted a PRP title search by reviewing historical records from the County Court House, the OCC, and the Oklahoma Tax Commission. The County Court House records could provide that last person or entity that became an “assignee” for the Oil & Gas leases were wells are located. The OCC records could provide that last owner and/or operator that produced or attempted to produce the well by filing a transfer petition and the OK Tax Commission could show which entity or person has had a sale of oil from a particular lease. So far, EPA has conducted a PRP search on 199 wells from which results have provided viable information to issue 51 Notice of Federal Interest (NOFI) letters under the Clean Water Act authority, as amended by the Oil Pollution Act, to 32 different persons or entities that could be a PRP. Several of the NOFIs have already been replied to providing information that some wells will be addressed by an RP, but many indicate that the leases or wells have been transferred to a defunct entity, thus abandoned.

EPA is now in the process of securing additional funding to initiate P&A activities on those wells to be addressed by EPA. Field work is set to resume within the next several weeks. In addition, wells within a few small properties in 5 Sections still need to be reassessed since extreme winter weather hindered the progress of the reassessment in January of 2010. EPA decided to wait until the start of P&A activities to resume and complete those reassessments. Based on observations in the field, it is not expected that many wells are to be added to the list of wells to be addressed by EPA.

2. Current Activities

2.1 Operations Section