Hazardous Waste Cleanup: HOVENSA, LLC 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 HOVENSA, under EPA oversight, pursuant to requirements in the facility's 1999 Resource Conservation and Recovery Act (RCRA) Operating Permit.
A major facility-wide Interim Corrective Measure (ICM), referred to as the "Hydrocarbon Recovery Project" (HRP), is on-going, under requirements of the facility’s RCRA permit. Based on the most recent semi-annual corrective action status report (February 2012), through December 31, 2011 a cumulative total of 43.212 million gallons of PSPH have been recovered from the groundwater under HOVENSA and recycled back into the facility's process stream. 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 release over time, from storage and process areas, as well as the underground “oily-water” sewer system. Based on the most current estimates made by HOVENSA (as of December 31, 2011), only approximately 306,000 gallons of recoverable PSPH still remain on the groundwater underlying the facility.
Since 1996, historical groundwater modeling studies and well data have shown that the PSPH plumes have been prevented from migrating off the 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 DPHC in wells located along the facility's perimeter, to confirm that off-site migration is not occurring. Prior to 1996, historical groundwater modeling studies indicate that some off-site migration of PSPH did occur along the western boundary of HOVENSA, but that migration only impacted the former St. Croix Alumina industrial site (now owned by St. Croix Renaissance Group LLC).
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 HOVENSA and the former St. Croix Alumina industrial site. EPA expects HOVENSA will be required to continue the PSPH recovery and maintenance of “hydraulic control” at its site following the cessation of refinery operations there.
The 1999 RCRA permit includes extensive corrective action requirements for solid waste management units (SWMUs) and Areas of Concern (AOCs) at the HOVENSA site. 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 and then HOVENSA have operated a facility-wide groundwater and hydrocarbon recovery system to clean up the underground PSPH/oil plumes. Continued operation of the facility-wide groundwater and hydrocarbon recovery system is required under its 1999 RCRA operating permit.
HOVENSA has 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.
The most recent semi-annual status report (February 2012) on HOVENSA's hydrocarbon recovery program required under its RCRA Permit indicates that, as of December 31, 2011, HOVENSA, under EPA oversight:
- has recovered 99% (43.212 million gallons) of the released underground oil, with only an estimated 306,000 gallons of recoverable oil currently remaining underground, but being hydraulically contained so as to prevent migration off the HOVENSA site, while continuing to be actively recovered;
- operates 100 “dual-phase” pumping wells, whose purpose is to recover the underground oil and dissolved constituents in the groundwater and prevent their off-site migration;
- operates 17 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;
- maintains 573 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 101 dissolved constituent monitoring wells, including 15 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 HOVENSA's northern "fence line" and are sampled every six months to insure that if DPHC or PSH were to migrate [upgradient] towards the Barren Spot well field, they would be detected;
- since 1994 have 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 HOVENSA site; and
- 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, in order to prevent future underground releases.
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.
Although cleanups had 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. Although EPA had public notice proposed final remedy criteria for the facility-wide groundwater plumes (AOCs #1, 2 & 3) in 2008, those proposals have not been finalized, due to objections made in 2008 by the VIDPNR. HOVENSA will continue to be responsible for completing the corrective action and RCRA closure requirements, even after the facility shuts down. EPA expects to announce a new public review on proposed remedies for the facility-wide groundwater plumes (AOCs #1,2 & 3) either late in 2012 or early 2013.
The HOVENSA facility ("the facility") is located at Limetree Bay, St. Croix, U.S. Virgin Islands. It is a petroleum refinery covering 1,500 acres in what is known as South Industrial Complex, on the south central coast of St. Croix.
Operations at the facility began in 1965 under 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. As of February 17, 2012 all refining and processing operations had ceased.
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. HOVENSA operates a 45 to 60 foot deep harbor which can accommodate super tankers at two of the nine berths. All transportation of crude and finished products is accomplished by means of tanker ships.
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, since 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 I 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. Since then, HOVENSA has submitted several revisions to the 2009 permit application, most recently in December 2011, based on EPA’s comments and instructions, so as to have the permit fully compatible with all EPA requirements necessary to protect human health and the environment.