Pollution/Situation Report Profile

Winganon Oil Spill Project
Winganon, OK - EPA Region VI
POLREP #4
Progress (re-start of project)

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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 #4
Progress (re-start of project)
Winganon Oil Spill Project
V6KC
Winganon, OK
Latitude: 36.5797986 Longitude: -95.5333757

To:

From:

Roberto Bernier, FOSC

Date:

9/13/2010

Reporting Period:

September 7 - 20, 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 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) but 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 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 to 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. As of April 2010, few smaller properties have not been reassessed yet for logistical reasons and the team decided to wait until the start of field activities (P&A) to resume the reassessment.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

On April 20, 2010 EPA and contractors remobilized to the site to initiate P&A activities on those wells that did not have a viable RP. P&A consists of removing the old tubing and cementing to the bottom of the well until it circulates to the top thru the back casing if one exists. Then, the cement is allowed to set, the well is "top-off" with more cement to later be cut at 3 feet below grade and capped with a welded ID plate.

During the period of April 20, 2010 to May 26, 2010, a total of 15 wells were P&A. These wells were located within project areas 05 and 25. Due to Deepwater Horizon Gulf Response, EPA suspended plugging activities for approximately three months to concentrate resources and manpower for that response. On May 27, 2010, EPA and contractors demobilized from Wingannon Project.

2.1.2 Response Actions to Date

Work began on an abandoned lease on Section 5 T23N R 17E of Rogers County or EPA Project Area (PA) 05 of the original Phase I of the Oologah Oil Spill Project. On PA 50, fourteen wells were determined needed to be addressed by EPA and as of April 27, six wells have been already P&A with two more already cemented. It is expected that work be completed in PA 05 by the beginning of next week.

As mentioned above, 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.

On Setember 7, 2010 EPA and contractors remobilized to the site to continue P&A activities of wells identified as abandoned and without viable RP. Due to heavy rain in the area, plugging was delayed for two days but the team concentrated on reconnecting with property owners, inspecting RP work, restoring the data, and conduct repairs to the CP after vandals broke into it few weeks before remob. On September 10 plugging activities resumed for wells at PA 25. As of September 20, four additional wells have been cemented for plugging, with two of them P&A. Two more remain to be plugged before moving the equipment to PA 13 where P&A activities will continue. A total 18 abandoned and unsecured or leaking wells have been P&A since the start of hte project.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

EPA continues to search for additional PRPs and to coordinate with active RPs to verify that their work to secure the wells within their responsibility is performed properly. As of today, seven RPs or active operators have been identified that are working to secure their wells that were identified by EPA during the reassessment.

Upon returning to the site after the break on September 7, EPA noticed that several of the identified viable RPs have secured and cleaned up most of the wells under their responsibility. OSC Bernier is in the process of coordinating with those RPs for them to provide final completion report for our records and conduct a final inspections of the RP wells.

2.2 Planning Section

2.2.1 Planned Response Activities

There is one well in PA 05 that after plugging is off gassing, therefore well has not been cut and capped. Three more wells to be addressed by EPA in PA 25.

2.2.2 Next Steps

The next Project Area (PA) to be addressed have already been indentified. Seven wells are located within PA 24 or Sec 17 T24N R17E. Twenty six wells are located within PA 13 or Sec 30 T24N R17E.

2.2.3 Issues

Because of rain events, it is expected for field activities to have some schedule delays due to accessibility issues for heavy equipment, and due to safety reasons.

2.3 Logistics Section