Hazardous Waste Cleanup: HOVENSA Environmental Response Trust, in Christiansted, U.S. Virgin Islands
On this page:
- Cleanup Status
- Site Description
- Contaminants at this Facility
- Site Responsibility
The site is being addressed by the HOVENSA Environmental Response Trust (ERT), under EPA oversight, pursuant to requirements in the facility's 1999 Resource Conservation and Recovery Act (RCRA) Operating Permit, as amended.
A major facility-wide Interim Corrective Measure (ICM), referred to as the "Hydrocarbon Recovery Project" (HRP), is ongoing under requirements of the facility’s RCRA Permit. Based on the most recent semi-annual corrective action status report (February 2021), through December 31, 2020 , more than 1,060,481 barrels (44,540,167 gallons) of phase-separated petroleum hydrocarbon (PSPH) have been recovered from the groundwater at the Site since inception of the hydrocarbon recovery program in the 1980s. This represents a recovery of an estimated 99% of the PSPH which was indicated to have been released to the groundwater through slow leaks and other releases over time, from storage and process areas, as well as from the underground “oily-water” sewer system.
Since 1996, historical groundwater modeling studies and well data have shown that the PSPH plumes have been prevented from migrating off the former HOVENSA site through active groundwater pumping to maintain “hydraulic control”. As part of the ICM, groundwater is monitored every six months for both PSPH and dissolved petroleum hydrocarbon (DPHC) in wells located along the facility's perimeter to confirm that off-site migration is not occurring. Additionally, due to the success of ongoing groundwater remediation efforts, the HOVENSA ERT has discontinued groundwater recovery at a number of wells where monitoring results indicate that concentrations of contaminants have stabilized.
Historical groundwater modeling studies indicate that some off-site migration of PSPH did occur along the western boundary of HOVENSA prior to 1996, but that only the former St. Croix Alumina industrial site (now owned by St. Croix Renaissance Group LLC) was impacted by this migration. The PSPH and any DPHC plumes on the former St. Croix Alumina industrial site are being addressed under a 2001 RCRA Consent Order between EPA and various past owners and operators of both the former HOVENSA and the former St. Croix Alumina industrial sites.
The 1999 RCRA permit, as amended, includes extensive corrective action requirements for solid waste management units (SWMUs) and Areas of Concern (AOCs) at the HOVENSA site. Interim cleanup goals have been based on site usage remaining industrial and are designed to prevent unacceptable risks to human health or the environment under industrial usage of this site. However, if future site usage changes, those cleanup goals may need to be re-evaluated.
EPA first became aware of the underground PSPH/oil plumes at HOVENSA (formerly Hess Oil Virgin Islands Corp. [HOVIC]) in 1982. HOVIC commenced limited PSPH (oil) recovery activities in 1982. Since 1987 HOVIC, HOVENSA, and the ERT have consecutively operated a facility-wide groundwater and hydrocarbon recovery system to stabilize and clean up the underground PSPH/oil plumes. Continued operation of the facility-wide groundwater and hydrocarbon recovery system is required under the 1999 RCRA Operating Permit.
In 2016, after the HOVENSA bankruptcy, the HOVENSA ERT was set up to manage the remediation of legacy contamination at the former HOVENSA facility.
The HOVENSA ERT, and formerly HOVENSA, have acceptably demonstrated to EPA, by groundwater modeling studies and monitoring well data, that the hydrocarbon recovery system maintains hydraulic control along the boundaries of the facility, and prevents off-site migration of not only underground oil, but also any dissolved constituent plumes in the groundwater itself. The hydraulic control is continuously maintained and monitored. Additionally, as noted above, due to the success of ongoing groundwater remediation efforts, the HOVENSA ERT has discontinued groundwater recovery activities at a number of wells where monitoring results indicate that concentrations of contaminants have stabilized.
The most recent semi-annual status report (March 2021) submitted by the ERT regarding the hydrocarbon recovery program required under the RCRA Permit, indicates that, as of December 31, 2020, the responsible entities of HOVIC, HOVENSA and now the ERT, under EPA oversight:
- has recovered 99% (44.5 million gallons) of the released underground oil.
- operates 37 pumping wells, whose purpose is to recover the underground oil and dissolved constituents in the groundwater and prevent their off-site migration.
- operates 24 vacuum extraction wells, which in addition to recovering underground oil and dissolved constituents in the groundwater, also recovers petroleum vapors and free oil located in the soils above the water table.
- operates one solar sipper and maintains and monitors a system of Baroballs™, sorbent booms, and sorbent socks.
- maintains 642 fluid “observation wells”, where fluid levels are measured in order to track the underground oil's areal extent and thickness distribution.
- samples the groundwater in 61 dissolved constituent monitoring wells, including16 wells around the facility's perimeter, every six months to measure the distribution and concentration of dissolved phase hazardous constituents (DPHC) in the groundwater itself. Six (6) of these dissolved constituent monitoring wells are located directly along former HOVENSA's northern fence line and are sampled every six months to ensure that if DPHC or PSH were to migrate [upgradient] towards the Barren Spot well field, they would be detected.
- since 1994 has developed a major facility-wide groundwater/phase separated [i.e., oil]/dissolved phase computer modeling project to guide and assess the efficiency of the cleanup, and verify that hydraulic control is being maintained so as to prevent migration of the oil and dissolved constituent plumes off the former HOVENSA site.
- since 1994 has been implementing a recurring program of pressure testing, and repair or replacement of all underground process sewers and hydrocarbon pipelines, as well a recurring program of internal inspection and testing of all hydrocarbon storage tanks at the facility to prevent future underground releases.
Although cleanups have been ongoing for a long time, final remedy decisions have not been made, except for several releases from solid waste management units (SWMUs), of limited areal extent. In February 2008, EPA public noticed proposed final cleanup criteria for the site-wide PSPH and DPHC plumes, which are being addressed as Areas of Concern (AOCs) #1, 2, and 3. A Public Meeting was held on March 12, 2008 in St. Croix to discuss the proposed final cleanup criteria for AOCs #1, 2, and 3; however, due to objections at that time by the public and the Virgin Islands Department of Planning and Natural Resources (VIDPNR), EPA did not finalize its approval of the 2008 proposed final cleanup criteria for AOCs #1, 2, and 3. The ERT is responsible for completing the legacy corrective action and RCRA closure requirements at the Site.
The former HOVENSA facility ("the facility") is located at Limetree Bay, St. Croix, U.S. Virgin Islands. It is a petroleum refinery covering approximately 1,500 acres in what is known as South Industrial Complex, on the southcentral coast of St. Croix.
Operations at the facility began in the mid-1960’s under Hess Oil Virgin Islands Corporation (HOVIC). On October 30, 1998 Amerada Hess Corporation, the parent company of HOVIC, and Petroleos de Venezuela, S.A. (PDVSA) formed a new corporation named HOVENSA LLC, which acquired ownership and operational control of the HOVIC facility.
The facility's maximum design capacity was 545,000 barrels (1 barrel = 42 gallons) of crude oil per day. Over 60 different types of crude oil had been processed at the facility. By means of distillation and other refining processes, crude oil is separated into various components. Light ends (fuel gas) are sent to the facility's fuel system; naphtha, jet fuel, kerosene and No. 2 oil are further processed to remove sulfur.
On January 18, 2012 HOVENSA announced that it was shutting down all refining and processing operations, but that it would continue to use certain portions of the facility as a petroleum storage terminal. HOVENSA ceased all refining and processing operations by February 17, 2012. In the months following, HOVENSA removed all hazardous wastes from the process units as well as from the storage tanks that were not utilized as part of the petroleum storage terminal.
In 2106, the HOVENSA Environmental Response Trust (ERT) was established, with the responsibility of managing HOVENSA’s legacy contamination. The ERT is responsible for continuing the remediation of contaminated groundwater, as well as managing the closed land-based units. The land-based units consist of three closed surface impoundments as well as three landfarms which are in post-closure care.
On September 15, 2015, HOVENSA, L.L.C. filed a voluntary petition for relief under Chapter 11 of the United States Bankruptcy Code in the District Court of the Virgin Islands, Bankruptcy Division [Case No. 15-10003]. As part of the Chapter 11 Section 363 process, a court-supervised auction of HOVENSA’s assets resulted in a sale of all terminal assets and above ground refinery assets located at the Site. The Asset Purchase Agreement (APA) was executed on January 4, 2016, and, as party to the APA, Limetree Bay Terminals, LLC became the owner and operator of all terminal assets and above-ground refinery assets as defined in the APA. HOVENSA, L.L.C.’s Chapter 11 Liquidation Plan, confirmed by the Court on January 20, 2016, provided for the creation of the HOVENSA Environmental Response Trust (ERT) and the ERT maintains the responsibility for certain HOVENSA legacy environmental requirements.
After the January 4, 2016 transaction, Limetree Bay Refining, LLC was formed in 2018. On November 30, 2018 the above-ground refinery assets were transferred from Limetree Bay Terminals, LLC to Limetree Bay Refining, LLC.
Land use north, east and west of the site is varied including commercial, residential and some light agriculture. The Caribbean Sea forms the southern border of the facility.
Contaminants at this Facility
As a result of relatively slow leaks from process and storage areas, as well as from the underground “oily-water” sewer system, extensive phase separated petroleum hydrocarbon (PSPH) plumes (also known as "oil") are present floating on top of the groundwater underlying the facility, and dissolved phase hydrocarbon constituent (DPHC) plumes are present within the groundwater itself.
Although not utilized for many years, former drinking water wells are present at the Barren Spot well field, located just north of the HOVENSA facility. There is little potential for a threat to the Barren Spot wells as they are hydraulically upgradient of HOVENSA. Nevertheless, any threat from HOVENSA would be detected by a series of monitoring wells located along HOVENSA's northern perimeter, which are sampled semi-annually to see if dissolved phase hazardous constituents or free oil are present. In addition, an ongoing program of leak detection and repair is designed to prevent or minimize further releases.
Site Responsibility at this Facility
Cleanup at this site is being addressed by the U.S. Environmental Protection Agency (EPA), under authority of the Resource Conservation and Recovery Act (RCRA).
On May 26, 1999, EPA Public Noticed its intent to issue HOVENSA a renewed hazardous waste operating permit pursuant to Resource Conservation and Recovery Act (RCRA). HOVIC obtained its original RCRA hazardous waste operating permit from EPA in 1988, authorizing the facility to continue operating Landfarms II and III for the land treatment of hazardous and nonhazardous petroleum refinery waste. Landfarm 1 has been closed and is regulated under a separate RCRA post-closure permit issued by EPA in 1990.
The renewed Final RCRA Operating Permit was issued by EPA on September 30, 1999, for a ten-year term. The 1999 RCRA permit remains in effect because, as allowed under RCRA regulations, HOVENSA submitted an application for a renewed RCRA Permit in May 2009.
Under the Environmental Response Trust Agreement, filed with the Bankruptcy Court and effective February 17, 2016, the ERT has assumed responsibility for certain environmental requirements at the Site including the activities required by the RCRA related to pre-existing groundwater contamination and the land treatment units (Landfarms 2 and 3). On May 2, 2017, EPA approved a Class 1 Permit Modification effectively transferring the Permit to the HOVENSA Environmental Response Trust (ERT). The Landfarm I post-closure Permit was also transferred to the ERT on May 2, 2017.
Since the RCRA Operating Permit was issued on September 30, 1999, several revisions to the 1999 permit have been approved by EPA, most recently in May 2019, for the closure of Landfarms 2 and 3, and the addition of one new perimeter monitoring well.