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2.1.1 Narrative
Following the threat determination made by OSC Delgado, EPA took actions in preparation to potentially conduct removal activities at the orphaned production facility in order to mitigate the actual or substantial threat of release of oil into navigable waters of the US. The response actions included: research of site history, records search for responsible party (RP), and landowner research; issuance of Notices of Federal Interest (NOFIs), identifying RPs; and acquired consent for access to property form surface owner.
2.1.2 Response Actions to Date
In December 2009, EPA FOSC Chris Ruhl visited the United Facility determined from his reconnaissance that the facility posed a threat of release, thereby prompting a site assessment.
In January 2010, EPA utilized their START contractor to conduct a site assessment. After review of site assessment data, FOSC Ruhl determined that the facility does have deficiencies, but does not meet the EPA Region 6 substantial threat criteria and no further action at the facility and will refer the site back to LDNR.
In April 2015, FOSC Delgado conducted a follow-up removal site inspection of the facility, at the request of LDNR. Based on site observations that included inadequate secondary containment overgrown with vegetation and eroded berms; deteriorating condition of AST; inactive and abandoned status of the facility; and the facility’s relative location to navigable water of the US, OSC Delgado determined that the facility met the substantial threat criteria required for removal action.
On 26 June and 1 July 2015, EPA issued 7 NOFIs via certified mail to the last operator of record. The last operator of record was discovered through RP research conducted by reviewing LDNR Lafourche Parish Clerk of Court records.
On 9 July 2015, EPA was granted consent for access to property from the landowner, which was verified through information gathered from the Tax Assessor’s office.
By September 2015, none of the NOFIs issued via certified mail on 26 June and 1
July 2015 were delivered to the last operator of record. Based on the threat posed by the abandoned
facility; the unresponsiveness of the same operator for another abandoned
facility where EPA conducted a removal action under FPN E09617; and the lack of
response to these NOFIs, EPA determined a RP-lead clean-up would not be
conducted in a timely manner and an emergency removal action was warranted to remove
the threat of the discharge of oil into a navigable waterway.
August 31, 2016 - Due to unforeseen delay in schedule and weather, the removal action was delayed until summer 2016. Due to OSC Delgado's schedule, the removal was transferred to the oversight of OSC Bryant Smalley. A work plan has been developed and an increase in funding requested to schedule the removal action.
September 26-29, 2016, EPA mobilized contractors
to conduct a removal of the AST and oil containing equipment at the
facility. The site was cleared of heavy vegetation
to provide access to the production equipment. Oil and production fluids were
removed from the AST and separators by vacuum truck and sent for disposal. Tank
bottoms and solids were loaded in a roll-off and transported for disposal. The
AST had to be cut in half to remove the solids.
Afterwards the AST was cleaned of gross oil contamination, crushed and
all metal was sent for recycling. The Site was regraded and personnel were
demobilized.
Wells 212993 and 213022
were not leaking and do not currently appear to pose a threat to Waters of the
US. Therefore, no action was taken on
the wells.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (RPs)
LDNR and Lafourche Clerk of Court records indicated the United Facility and its associated wells were last operated by United Production Company (LDNR Organization ID U028). EPA issued 7 NOFIs to representatives and business addresses identified during the RP search. As of 01 September 2015, none of the NOFIs were delivered. Of
the seven NOFIs issued via certified mail, three were unable to be delivered
and returned; three were returned because they were never picked-up and
exceeded maximum holding time at the post office; and status of one is unknown,
but believed to be lost and undelivered.
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