|
|
|
2.1.1 Narrative
At this time, an abandoned oil/gas well has been identified under the structure, the pipe from the culvert has been determined to originate from the area of the subject well, the temporary vent stack continues to suitably allow gas to exit the structure, Oil has been found migrating within and alongside the pipe between the well and the culvert. EPA continues to monitor the air and maintain containment and removal of oil from Stackyard Hollow.
2.1.2 Response Actions to Date
See Prior POLREPs for activities through July 6, 2015.
A perimeter air monitoring plan was developed in order to monitor the community for any potential airborne health hazards during removal activities. AreaRae units would be utilized in order to monitor and screen for hazardous constituents in the air, including VOCs and benzene. Peak benzene levels were determined as recommended by Acute Exposure Guideline Levels (AEGLs) and discussed with ATSDR. To protect the public from a potential explosive atmosphere created by Site activities, %LEL would be constantly monitored. EPA START contractors would conduct the air monitoring daily during all removal activities, using a radio link to a computer system which would facilitate real-time monitoring of all Area Rae units.
On July 7, 2015, the OSC met with the EPA cleanup contractor (a/k/a ERRS), ERRS' subcontractor, and EPA's technical support contractor (a/k/a START) on Site. Measurements were taken from the interior of the structure in order to facilitate use of equipment. Site safety zones, staging areas, and air monitoring locations were identified. Following the Site visit, the OSC coordinated with both ERRS and START in order to finalize a Site Health and Safety Plan.
During the week of July 7, 2015, the OSC and START visited neighboring residents in order to provide a Residential Handout that summarized the dates/times of removal activities, things to look for, safety issues, and efforts being made to assure healthy air quality. The OSC provided the final Community Air Monitoring Plan to local officials and provided them opportunity for comment.
On July 13, 2015, ERRS and its subcontractor mobilized to the Site. ERRS arranged for delivery of a vacuum box and vacuum truck to the site. ERRS will use the high powered vacuum system to remove oil and debris from the well. ERRS staged all equipment on Site in a manner that did not impede traffic on Joan Street. ERRS constructed a containment area for the vacuum box and 55-gallon drums. START mobilized to the Site and staged air monitoring equipment in a directional pattern of north, south, east, and west of the structure, in order to monitor vapor emissions from the structure towards all neighboring residents. ERRS installed ventilation and air control systems by placement of a pneumatic fan in the window of the structure, which prevented build-up of vapors inside the structure; one of the air monitoring units was placed directly east of the fan. Additional boom was deployed in Stackyard Hollow to contain fluids that could potentially be released from beneath the structure.
Initial Site activities included hand-digging the soil around the well to a depth of approximately two feet, placing a 12" well control head over and around the existing 10" casing, and cementing the new well control head in place. The vacuum truck was utilized to remove the top layer of fluids from the wellbore and to remain on standby to contain any potential discharge of fluids from the well. The oil-contaminated soil from the area surrounding the well head was secured in 55-gallon drums. Throughout the day, air monitoring from the community AreaRae's did not record any levels of VOCs or %LEL above 0. Worker safety during site operations in the structure was monitored with a mobile MultiRae; VOCs in the breathing zone did not exceed 5ppm for a duration in excess of one minute and 0%LELs were noted during all operations.
On July 14, 2015, a high power vacuum truck was mobilized to the Site. ERRS' contractors connected a series of 6" vacuum hoses from the well location to the vacuum box, then to the vacuum truck. Initially, vacuum operations were not successful due to large stones and bricks present in the top 10 feet of the wellbore; ERRS' contractors used hand tools to remove this large debris. Following, vacuum operations proceeded. The contractors constructed a small hand drill system using a frame and pulleys to raise and lower a bit weighing about 130 pounds. This action was used to break through several blockages. On several occasions, debris larger than the mouth of the hose caused hose clogging and collapse of the hose. ERRS' contractors attempted to use PVC pipe at the end of the corrugated vacuum hose to minimize pipe collapse of the vacuum line. Mechanical problems with the vacuum truck caused a stoppage in operations in the late afternoon of 7/14. Throughout the day, air monitoring from the community AreaRae's did not record any levels of VOCs or %LEL above 0. Worker safety during site operations in the structure was monitored with a mobile MultiRae; VOCs in the breathing zone did not exceed 5ppm for a duration in excess of one minute and 0%LELs were noted during all operations.
An official from the City of Wheeling Health Department visited the Site prior to the afternoon operations commencing. The official was shown the air monitoring equipment and informed of the associated data for VOCs and %LEL. He was also informed of the VOC and LEL levels inside the structure; no issues were presented.
On July 15, 2015, a replacement vacuum truck was mobilized to the Site. Use of the PVC pipe was successful for a short time, but as the weight of the pipe increased and the length of the pipe was restricted, ERRS' contractors returned to a string of 6" vacuum hose. Vacuum operations continued in an attempt to remove debris, rock, and oil from the wellbore. Pieces of concrete were also removed. An estimated depth of 52 feet was attained by late afternoon. However, each time the vacuum hose was moved up and down the wellbore, it seemed the sides of the wellbore caved in; recovery of rock and debris continued but additional depth could not be achieved. A measurement was taken inside the wellbore; a depth of 49 feet was achieved when the OSC decided to conclude operations. Upon visual inspection of the inside of the wellbore, it was confirmed that the sides of the wellbore were caving in just below the 10" string of casing. It was determined that the entity who abandoned the well had pulled all of the casing out of the wellbore, with the exception of the top 10" string. EPA, ERRS, and ERRS subcontractor met to evaluate the situation and discussed options. It was determined that due to caving of the wellbore and restrictions of the pressure in the vacuum hose at a depth greater than 50 feet, further attempts to clear out the wellbore were not possible utilizing this removal method. Operations ceased. ERRS and its subcontractors decontaminated their equipment and the vacuum truck was demobilized from the Site.
Air monitoring results from July 15, 2015, included two occurrences when the VOCs exceeded 16 ppm, up to 136.9 ppm and 49.1 ppm for a period of 5 seconds, on the AreaRae located north of operations. START immediately screened for benzene using Drager tubes; 0 ppm benzene was detected in both instances. Operations that were occurring during these peak VOC detections were during pumping operations of fluids into the vac box and removal of the 50 feet of vacuum hose from the wellbore. Exceedance of 5 ppm VOCs did not extend longer than a period of two minutes on either occasion.
On July 16, 2015, EPA, WVDEP, and ERRS continued to evaluate removal options. Further discussions and evaluation would follow. ERRS and its plugging contractor demobilized all equipment from the Site. Remaining on Site pending T&D were the vac box with fluids and debris, and five 55-gallon drums containing oil-contaminated soil. ERRS collected samples for disposal of the soil. ERRS began to make arrangements for recycling of the fluids in the vac box and T&D of the remaining oily solids.
The OSC is continuing to evaluate next steps.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The OSC continues evaluation of available information. There is no specific map of the oil facility along Joan Street. A Sanborn fire insurance map from 1922 shows several wells along Joan Street likely including the subject well. A geologic map from 1968 shows that all wells near Stackyard Run are abandoned.
Through a courthouse deed and lease search, the well was found to exist on Lots # 4 and #5 alongside Stackyard Run.
A facility is described to mean any structure, group of structures, equipment, or device which is used to explore for, drill for, produce, store, handle, transfer, process, or transport oil.
The owner / operator is defined (very simply) to be the owner or operator of a facility including any person owning or operating the facility. The owner or operator of any abandoned facility is the person who owned or operated the facility immediately prior to its abandonment.
For an on-shore facility, the Responsible Parties are any persons owning or operating the facility (except for a government owner transferring rights under a lease agreement). For an abandoned facility (2701(32)(F)), the responsible party is the person who would have been responsible immediately prior to abandonment.
The OSC has conducted effort to identify potentially Responsible Parties for this incident to the extent practicable.
A lease agreement executed May 28, 1910 between Hilton (lessor) and Seybold (lessee) contained, among other things, the following terms and conditions:
1. One year term and as much longer as oil or gas is found in paying quantities.
2. A requirement to drill a well within 4 months.
3. 1/8th part or share of the oil to be paid to the lessor.
4. The right for the lessor to drill and operate for oil, lay and maintain pipelines, and build structures.
5. The right to remove, at any time, any machinery, structures, or fixtures placed by the lessor.
All terms and conditions of the lease extend to the heirs, successors, executors, administrators, and assigns of the two parties.
An oil well (“the well”) was installed at the incident location (along Joan Street adjacent to Stackyard Run) sometime prior to June 1911 as referenced in a document conveying 3/4th interest in the producing well from Seybold (lessor) to Octo Oil Company . The remaining 1/4th interest was conveyed to Octo Oil Company in 1913. The well was subject to the rights, terms and conditions of the 1910 lease agreement.
The well was part of an on-shore oil and/or gas production facility (“on-shore production facility”). Other wells which were part of the on-shore production facility were subject to the terms and conditions of other lease agreements. In 1916, the Octo Oil Company conveyed several wells and the rights under several lease agreements (including the well and relating 1910 lease agreement) to Glenwood Oil and Gasoline Company.
A map of the area dated 1922 depicts several wells along Stackyard Run. A trustee of the Glenwood Oil and Gasoline Company conveyed the real and personal property of Glenwood Oil and Gasoline Company to A. Schmidt in 1923. The conveyance included wells and equipment and leases covering several different pieces of land (owned by different landowners), a gasoline plant and station, and several parcels of land.
The primary terms of the various leases and agreements relating to the on-shore production facility were expired by 1921.
In 1923 and 1925, Schmidt sold parts of the former Glenwood Oil and Gasoline Company property (specifically identified as certain parcels of land) to others. The well is located on one of these parcels.
A map dated 1968 identifies several abandoned wells in the area of Stackyard Run indicating the abandonment of the on-shore production facility (no official record of such activity was required by the State prior to 1929). The facility was likely abandoned by the early 1920s as the area became a part of the City of Wheeling and was developed for residential use. Additionally, the primary lease terms and agreements providing the rights to operate for oil along Stackyard Run were expired by 1921.
Documentation to verify the ownership and operational status of the well is scant. Records were not required by the State until 1929. The State of West Virginia Department of Environmental Protection (“WVDEP”) considers the abandoned well oil and/or gas well to be an “orphan” well (e.g. no known or otherwise viable owner/operator).
The well was identified as a producing well in 1911 and was passed to an oil company (Glenwood Oil and Gasoline Company) that may have operated the well in 1916. The Glenwood Oil and Gasoline Company sold its properties through a trustee in 1923 and that is the likely time period during which the well and the relating on-shore production facility were abandoned. Other wells in the area have been found to be properly plugged indicating proper actions by the owners/operators. Wells in the area of Stackyard Run are identified as “abandoned” on a map produced in 1968. In any event, a building was constructed on top of the remains of the well in 1964 indicating that the remains of the on-shore production facility had already been removed from the land by 1964.
The OSC concludes that the Glenwood Oil and Gasoline Company was likely the last owner/operator of the well/facility and that A. Schmidt was the last specific documented owner of the well/facility (likely abandoned). The OSC concludes that these entities are potential Responsible Parties. Glenwood Oil and Gasoline Company no longer exists. A. Schmidt is deceased. Persons identified in the will of A. Schmidt are deceased. The OSC was unable to send a notice to suspected discharger to these entities.
A multi-unit residential structure was constructed over the location of the well in 1964. Neither the abandoned well nor the abandoned on-shore production facility were appurtenant to the multi-unit residential structure based upon direct observations by the OSC (i.e., not physically or obviously connected in any way). A formed and poured concrete slab was installed as the foundation for the multi-unit residential structure and this slab was poured directly atop and a few inches from the top of the well providing no access thereto. The well was abandoned at some point in time prior to the construction of the structure used for residential purposes.
The abandoned well was located within the perimeter of the formed and poured concrete slab. At the time of the forming and pouring of the concrete slab, the well casing may have been exposed and visible at, above or below the ground surface. A 6-inch diameter pipe was found below the slab of the building running from the location of the down-gradient side of the abandoned well to (and through the wall of) a box culvert surrounding Stackyard Run. This pipe may have served to divert any fluids from the well towards and into the nearby perennial stream (a/k/a Stackyard Run; note that the pipe was found without protection and full of dirt and debris as well as oily material).
The abandoned well is currently discharging oil into Stackyard Run and releasing oil and natural gas into the multi-unit residential structure. The oil migrates up the well and from unknown locations adjacent to the well (likely a compromised casing) and into the surrounding soils between the well and Stackyard Run. Some oil also somehow enters the pipe and directly discharges to Stackyard Run. Stackyard Run is a navigable waterway of the United States.
The Person(s) who performed the construction of the multi-unit residential structure, were also likely aware of the existence of the abandoned well. The slab of the building and the soil drainage pipes from the building are very close to the position of the well. A section of 6-inch diameter pipe (unknown purpose) was also found running from immediately adjacent to the well (although not connected) towards and through the wall of a box culvert surrounding Stackyard Run. It appears that the 6-inch diameter pipe may have once served to carry fluids from the location of the well towards Stackyard Run. This pipe was placed before the slab of the building was poured although there was no precautions taken to assure the pipe remained open resulting in dirt, debris and concrete to be located within. The 6-inch pipe is not a part of the foundation of the building.
The constructors of the building in 1964 were likely the last persons to have seen the well prior to it being discovered under the slab of the multi-unit residential structure. The Person(s) who poured the concrete slab and who may have placed the 6-inch diameter pipe, may have information relating to the abandonment of the well and may have conducted a deliberate action to divert or discharge fluids from the well to Stackyard Run and/or to otherwise fill the wellbore with debris. The Karnell Company was dissolved in 1967 and its owner, and owner of the subject property on which the building was constructed (N. Karnell) is deceased. The OSC is unable to send Karnell Company or its owner a notice of suspected discharger.
The property was held by a trust benefitting the wife of N. Karnell until 2003 when it passed to a relative and his company. The property then passed in 2009 outside the Karnell family.
The current owner of the land and the multi-unit residential structure (since 2011) became aware of the problem(s) associated with the abandoned well sometime in 2013 as oil entered the residential building. The OSC initiated a preliminary assessment in January 2014. After investigations suggested the potential for a leaking oil well under the building, the owner of the multi-unit residential structure broke through the concrete slab around the perimeter of the well on the advice of the OSC. The well was then verified. The owner, with the advice of the OSC and WVDEP, installed a ventilation system to exhaust volatile organic compounds (VOCs) from the well to locations outside the structure to reduce the chance of fire and explosion.
The current owner of the land and multi-unit residential structure states that he was unaware of an oil well on the property until discovered under the building in 2014. There is no record of the well with the WVDEP. The deed records for the property do not mention an oil well, oil activity, or relating reservations since 1925. The well was not mentioned in a title search relating to the property. The structure has been built over the position of the well since 1964. The last persons to have likely seen the well were those that constructed the building in 1964. The OSC does not conclude that the present owner of the structure was an owner or operator of the well or facility defined to be the structure, group of structures, equipment, or device used to explore for, drill for, produce, store, handle, transfer, process, or transport oil.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| oil |
solids |
55-gallon drum |
|
|
X |
| |
|
|
|
|
|
| |
|
|
|
|
|
|
