2.1.2 Response Actions to Date
On 07/06/2016, PADEP-OGMP implemented defensive actions and
photo-documented conditions on-site.
On 07/19/2016, PADEP-OGMP
notified the National Response Center (NRC) and NRC #1153782 was assigned to
the incident. In follow-up to the
NRC Report, the OSC continued with the preliminary assessment including but not
necessarily limited to the following actions: using available information,
supplemented by an on-scene inspection, evaluated the magnitude and severity of
the discharge; assessed the feasibility of removal; continued efforts to the
extent practicable, to identify potentially responsible parties; determined
whether a state or political subdivision thereof had the capability to carry
out any or all removal actions (if so, the OSC may arrange funding to support these
actions); and ensured prompt notification of the trustees of affected natural
resources in accordance with the applicable RCP and ACP.
07/22/19, the OSC met PADEP-OGMP
on-site, continued preliminary assessment.
The OSC observed and photo-documented the discharge of crude oil from
the abandoned on-shore facility, determined the incident met the criteria for
funding under a federal removal action (PFRA) or otherwise reimbursement via
the Claims process. The OSC to continue to monitor the situation. PADEP-OGMP to continue to maintain defensive
actions and assist the OSC with efforts to identify potentially responsible
parties pending OSC’s availability to conduct on-site assessment.
08/09/2016, the OSC met with
PADEP-OGMP and DCNR on-site, continued preliminary assessment, and discussed removal
funding options (PRFA and Claims process) and the Natural Resources
Damage Assessment (NRDA) process. PADEP-OGMP to consider conducting the removal
action under a PRFA. PADEP-OGMP to pass information along to the State
Natural Resources Trustee for consideration of a NRDA.
On 08/09/2016, the OSC accessed CANAPS and obtained an initial project ceiling of $50,000 to continue removal assessment (e.g. feasibility of removal action); continue maintenance of defensive actions to mitigate the effects of a discharge and of the substantial threat of discharge of an unknown quantity of crude oil onto the adjoining shorelines of and into Cooks Run; continue efforts to the extent practicable to identify PRPs; continue efforts to the extent practicable to identify and provide the RP an opportunity to voluntarily and promptly perform removal actions; and/or in absence of a RR, conduct the removal actions necessary to mitigate the effects of a discharge and of the substantial threat of discharge of crude oil onto the adjoining shorelines of and into Cooks Run.
PADEP-OGMP to enhance and continue to maintain defensive
actions and arrange for the removal of the discharge, and mitigate or prevent a
substantial threat of a discharge, including but not necessarily limited to
plugging the abandoned (orphan) well.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
In accordance with the requirements of the NCP, the OSC, to
the extent practicable, continues efforts to identify potentially responsible
parties and provide the responsible party an opportunity to voluntarily and
promptly perform removal actions.
In accordance with the definitions of Responsible Party
found at Section 1001 of OPA, efforts to to identify the persons owning
or operating the onshore facility, and/or those persons who would have been
responsible parties, immediately prior to the abandonment of the facility continue.
The OSC’s efforts to identify potentially responsible
parties included evaluating if the current surface or landowner(s), the current
OGM rights owner(s) and/or any other person was the current owner/operator of
the onshore production facility.
2.1.4 Progress Metrics