EPA v. CALLON PETROLEUM OPERATING COMPANY / ST. CATHERINE CREEK OIL SPILL SITE

Case summary

9/16/19 - ADMINISTRATIVE ORDER ON CONSENT ISSUED. FINDINGS OF FACT: ON NOV 22, 2016, A REFUGE HUNTER DISCOVERED AN ABANDONED AND LEAKING OIL WELL LOCATED IN THE CLOVERDALE UNIT OF THE ST. CATHERINE CREEK NATIONAL WILDLIFE REFUGE AND REPORTED THE DISCOVERY THAT SAME DAY TO A FEDERAL WILDLIFE OFFICER WITH THE U.S. FISH AND WILDLIFE SERVICE (USFWS). PRIOR TO THIS TIME, USFWS REPRESENTATIVES WERE UNAWARE OF THE OIL WELL'S EXISTENCE DUE TO THE LARGE AREA (NEARLY 25,000 ACRES) OF THE REFUSE. THE FEDERAL WILDLIFE OFFICER SUBSEQUENTLY INSPECTED AND DOCUMENTED THE WELL SITE LOCATED AND CONTACTED THE NATIONAL RESPONSE CENTER. ACCORDING TO THE FEDERAL WILDLIFE OFFICER, THE OIL WELL WAS OBSERVED TO BE LEAKING CRUDE OIL FROM THE CASING THAT REMAINED IN THE GROUND IN A PORTION OF THE REFUGE LOCATED ADJACENT TO A WATERFOWL IMPOUNDMENT APPROX 1/2 MILE FROM ST. CATHERINE CREEK, WHICH LEADS DIRECTLY TO THE MISSISSIPPI RIVER. THE AREA WHERE THE WELL WAS DISCOVERED IS ANNUALLY FLOODED WITH WATER FROM THE MISSISSIPPI RIVER THAT CAN COVER THE LOCATION WITH 20 FEET OF WATER. FOLLOWING DELAYS DUE TO FLOODING OF THE AREA, WHICH PROHIBITED ACCESS TO THE OIL WELL LOCATION, ON FEB 22, 2017, EPA'S EMERGENCY RESPONSE AND REMOVAL BRANCH ARRIVED AT THE SITE TO CONDUCT AN ASSESSMENT OF THE OIL WELL AND ITS ASSOCIATED THREATS TO SURFACE WATER AND THE SURROUNDING ENVIRONMENT. DURING THE SITE VISIT, EVIDENCE OF HIGH-WATER LEVELS WERE OBSERVED, INCLUDING THE PRESENCE OF WATER STAINING ON TREE BRANCHES IN THE AREA OF THE OIL WELL APPROX 8 TO 10 FEET ABOVE THE GROUND SURFACE. ACCORDING TO USFWS REPRESENTATIVES, THE HIGH WATER HAD ONLY RECENTLY RECEDED, APPROX 1 WEEK PRIOR TO THE SITE VISIT. AT THE TIME OF THE SITE VISIT, THE OIL WELL LOCATION WAS STILL COVERED BY A SMALL POOL OF WATER SO THE CASING WAS NOT VISIBLE. BASED ON FIELD OBSERVATIONS DURING THE SITE VISIT, INCLUDING OIL OBSERVED ON THE GROUND SURROUNDING THE OIL WELL CASING, AS WELL AS DISCUSSION WITH THE DOCUMENTATION PROVIDED BY REPS OF THE USFWS FROM THEIR PRIOR VISITS, AN ONGOING RELEASE OF OIL WAS OCCURRING AT THE FACILITY, RESULTING IN A THREATENED DISCHARGE AND ACTUAL DISCHARGE OF OIL INTO ST. CATHERINE CREEK, THE MISSISSIPPI RIVER, AND/OR THEIR ADJOINING SHORELINES, CAUSING A FILM OR SHEEN ON THE WATER'S SURFACE. DURING AN ADD'L FOLLOW UP VISIT IN JULY 2018, EPA PERSONNEL AGAIN OBSERVED A FILM OR SHEEN ON THE WATER'S SURFACE AT THE FACILITY, AND AS A RESULT, BELIEVE THAT OIL CONTINUES TO DISCHARGE FROM THE FACILITY AND ENTER ST. CATHERINE CREEK, THE MISSISSIPPI RIVER, AND/OR THEIR ADJOINING SHORELINE BASED ON ANNUAL FLOODING CONDITIONS. SINCE THE JULY 2019 VISIT, DESPITE DELAYS DUE TO SITE CONDITIONS AND ACCESSIBILITY, EPA AND RESPONDENT HAVE WORKED TO MOVE FORWARD WITH THIS CONSENT ORDER AND THE WORK CONTAINED HEREIN. WORK TO BE PERFORMED: - WITHIN 3 WEEKS OF THE WRITTEN DIRECTION OF THE OSC THAT SITE CONDITIONS ARE SUITABLE FOR THE REMOVAL ACTIONS DISCUSSED HEREIN TO BEGIN, COMMENCE MOBILIZATION OF EQUIPMENT AND PERSONNEL NECESSARY TO CONDUCT PLUGGING AND ABANDONMENT (P&A) OPERATIONS AT THE SITE; - CONSTRUCT AN ACCESS ROAD IN ORDER TO TRANSPORT WORKOVER RIG TO THE OIL WELL; - RE-ENTER THE OIL WELL AND DRILL OUT PREVIOUS CEMENT PLUGS, AVOIDING TO DRILL OUT THE BOTTOM PLUG; - RUN CEMENT BOND LOG WITH COLLAR LOCATOR AND SET CAST IRON BRIDGE PLUG; - PERFORATE ANY SECTIONS OF CASING SHOWN BY BOND LOG TO BE INSUFFICIENTLY BONDED OT NATIVE ROCK FORMATIONS, AND BASE OF FRESHWATER INTERVAL (APPROX 1300') AND SQUEEZE CEMENT BEHIND PERFORATED CASING; - COMPLETELY FILL CASING STRING WITH CEMENT AND PLACE A MINIMUM 100' CEMENT PLUG IN THE 5 1/2 TO 8 5/8 ANNULAR SPACE; - CUT OFF ALL CASING 3 FEET BELOW GROUND SURFACE, SEAL CASING WITH A METAL CAP AND BACKFILL HOLE; - DISPOSE OF ANY OIL IMPACTED SOILS AT AN APPROPRIATE DISPOSAL FACILITY; - DEMOBILIZE RIG AND WORKOVER EQUIPMENT, REMOVE ACCESS ROAD, AND RESTORE AREA TO THE SATISFACTION OF THE EPA'S OSC.

Defendants (1)

• CALLON PETROLEUM OPERATING COMPANYNamed in settlement

Facilities (1)

• ST. CATHERINE CREEK/CALLON PETROLEUM OIL SPILL

  ST. CATHERINE CREEK NATIONAL WILDLIFE REFUGE, NATCHEZ, MS, 00000

  Registry ID: 110070616321

Statutes cited

• CWA 311B — Oil & Hazardous Substances Discharge
• CWA 311C2/311E — Emergency Powers Oil Imminent & Substantial Endangerment

Enforcement conclusions (1)

• CALLON PETROLEUM OPERATING COMPANY / ST. CATHERINE CREEK OIL SPILL SITEentered 2019-09-17

  Primary law: CWA

Timeline (2 milestones)

• 2019-09-17Final Order Issued
• 2019-10-02Enforcement Action Data Entered