BP Checks Contaminated Well Into Remediation
DEQ ‘volunteer ‘program offers future liability protection
by Joy Ufford

BP America (BP), which operates one of three industrial water wells found earlier this year to have unacceptable levels of the contaminant benzene, is taking steps to clean up its situation. In July, BP applied to have its contaminated water well Corona 2-14 accepted into the Wyoming Department of Environmental Quality’s (DEQ ) “Voluntary Remediation Program” (VRP), according to Mark Thiesse, DEQ’s West District supervisor for the groundwater section.

Thiesse’s role is to assist those operators with methods for coming into compliance with Environmental Protection Act (EPA) standards that the agency uses to determine safe drinking water standards; these are the standards all water wells are held to regardless of their uses, he said. The most recent test at Corona 2-14 showed a benzene level 15.4 parts per billion (ppb),“which is pretty high” compared to the DEQ standard of 5 ppb, said Hal Hatfield, VRP supervisor.

“The VRP was established to provide a safe and efficient method for cleaning up some contaminated sites and putting them back into productive use,” says its Web site.

VRP requires that a “public notice of voluntary cleanup” must be published; that notice was posted on Pinedale Online last week. BP must also inform neighbors on how to comment on proposed remedial actions and to request public participation in its VRP plan.

Testing, testing

Corona 2-14 is located about 30 miles south of Pinedale. Tests made of its water in October 2006 and January 2007 showed contamination levels of the hydrocarbon benzene at 346 ppb, far higher than allowed by the Wyoming Department of Environmental Quality (DEQ ).

In the 2006 tests, four water wells in the Pinedale Anticline showed higher-than-acceptable levels of contaminants, according to the Bureau of Land Management (BLM). DEQ then requested that all water wells be tested in the Jonah Field and the Pinedale Anticline project Area (PAPA). Test results released by the BLM in April showed that of about 163 wells tested in January, three wells – one each operated by BP, Ultra Resources and Shell – exceeded regulatory levels and that another 82 wells tested showed detections of hydrocarbons, particularly benzene.

The fourth well had been “pumped extensively” and came into compliance before the January tests, according to Merry Gamper, BLM supervisory natural resources specialist in Pinedale.

“Volunteers”

BP’s Corona 2-14 is the only one of the three contaminated wells currently enlisted in the voluntary program, according to Hatfield. The first stage of a preliminary agreement between BP and VRP includes monitoring the well, testing soils and searching for the contamination source, he said.

“Our initial review suggests that backflow utilizing our operating practices is not likely and the contamination source is unknown at this time,” BP Field Environmental Coordinator Don Brooks wrote in a June 14 letter to the DEQ/VRP.

The company is considering “other potential factors” such as surface pipe and well depth, water well hookups, fresh water tanks and other “operational practices,” Brooks wrote.

“As a note, this is one of 24 fresh water wells we operate with the same practices and the other 23 wells tested ‘nondetect...’” he wrote.

To prevent future contamination, BP will have an environmental consultant on hand when a new water well is drilled to ensure the process and equipment are not part of the problem, Hatfield said. Shell and Ultra are also working to comply with DEQ standards, Thiesse said. Ultra has hired a consultant to assist in applying for VRP; its well (WB7-15D) tested at 52 ppb for benzene in January.

As for the Shell water well, it tested at 6.6 ppb in November 2006 and according to the company’s latest test results, the benzene level is now at the “non-detect” level of .5 ppb or less, Thiesse said. Because it has come into compliance, Shell will not have to submit its well to VRP but instead will likely be required to conduct quarterly, then annual re-testing, he said. None of the three contaminated wells are in use at this time, Thiesse added.

Because the industry is turning to more re-use of recycled, cleaned industrial water, possibly the other 82 wells found to have hydrocarbons could be capped or plugged if no longer needed, he said. “We really don’t know (where the contaminants came from)’ Thiesse said of those wells. “But once you get (groundwater) contaminated it’s there for a long time.”

Remedies

As part of VRP enrollment, a remedy agreement is put into place and at that time the DEQ can issue participants a “covenant to not sue,” releasing “volunteers” from future liability.

First, proposed remedies must meet the EPA standards and could include institutional controls (such as zoning restrictions, control areas or deed notices) or engineering controls (such as capping, slurry walls or containment) or a combination of actions. The proposal is then formalized in a “remedy agreement,” which includes an action plan, description of controls to be used, a schedule, provisions to modify the agreement, financial assurances and other provisions that successfully implement the remedial actions, according to the VRP Web site.

Once the remedy agreement is reached, the DEQ can assure a “volunteer” it is released from liability. After a contaminated site complies with DEQ standards, the owner/operator can request a certificate of completion or a “No Further Action” letter from the DEQ.

What’s next

An interagency meeting is planned next week “to hash out this problem” of regulatory issues that will work across the board for the low-level contaminated wells, according to Gamper.

Those wells might need to be plugged and abandoned or retested at certain intervals, Thiesse said. “They are probably safe to use but the companies voluntarily shut them in,” he added. “We hate to plug them if there are only traces.”

As for BP, and soon, Ultra, participating in VRP calls for informing the public that “any interested party may request development of a public participation plan,” says the public notice of voluntary cleanup. Anyone wanting to request development of a public participation plan must do so no later than Oct. 8 by sending a written request to: LeRoy C. Feusner, P.E., BCEE Administrator, Solid and Hazardous Waste Division, DEQ, 122 W. 25th St., Cheyenne,WY82002.

For more DEQ/VRP information, contact Hal Hatfield at 307-335-6944, or for more BP America information, contact Don Brooks at 307-328-9646.