EPA Approves Refinery Chemical Removal Plan
Earlier this month, the U.S. Environmental Protection Agency announced that it has conditionally approved plans to safely remove dangerous chemicals from a refinery on St. Croix in the U.S. Virgin Islands.
The move arrives after the EPA entered into a legal agreement with Port Hamilton Refining and Transportation LLLP (PHRT) at the end of last year after an inspection identified several safety concerns, including pipe corrosion.
“This is a critical step forward in safely removing harmful chemicals from the facility and away from the community and workers,” said EPA Regional Administrator Lisa F. Garcia.
“EPA will be there every step of the way, providing oversight of the safe removal to ensure people’s protection. We will provide the public with updates and make real-time air monitoring data available to the community.”
Formerly known as the Limetree Bay Terminals and Limetree Bay Refining, LLC, the refinery is located in St. Croix in the U.S. Virgin Islands and was formerly the largest in the Western Hemisphere. It was expected to boost overall supply in the Caribbean, a key transit point for petroleum shipments, when it was built in the 1960s by Hess Oil.
However, the refinery was ordered by the EPA to pause all operations in May 2021, following multiple air emissions incidents due to the imminent and substantial endangerment to public health or welfare of the environment posed by continued refinery operation.
Since February 2021, the refinery reportedly experienced multiple major mishaps resulting in significant air pollutant and oil releases. The May case resulted in a “serious incident” that led to exceedance of the emission limit for sulfur dioxide (SO2), a potent toxic gas, endangering the health of nearby communities.
That order was then reportedly augmented and extended by the complaint and stipulation filed in July 2021.
The West Indies Petroleum Limited and Port Hamilton Refining and Transportation, LLLP (jointly WIPL/PHRT) then won the bid for the Limetree Bay refinery from an auction held in bankruptcy court on December 21, 2021, for $62 million.
In March of last year, the U.S. Department of Justice and EPA transmitted letters to WIPL/PHRT, summarizing a number of requirements to be met before restarting the refinery. Later that month, the EPA said, based on the information available to them, the refinery would potentially need to obtain a Prevention of Significant Deterioration (PSD) permit prior to any potential startup of refinery operations.
A PSD permit limits emissions to levels that would result from the best available air pollution control technology. The EPA said this would likely result in significant reductions of emissions of nitrogen oxides and volatile organic chemicals, and reductions in sulfur dioxide, hydrogen sulfide, carbon monoxide and particulate matter at the facility.
The EPA also reportedly asked for additional information from WIPL and PHRT regarding past and future changes to process and emission units at the refinery. This would enable the Agency to evaluate the issue further before making a final determination regarding the need for a PSD permit.
In September, the EPA inspected the facility to more broadly determine the general state of chemical safety at the facility. During the inspection, the Agency noted serious deficiencies in the way that this facility is being maintained.
These safety concerns included corrosion of piping and valves, which could result in a chemical release or fire, particularly where large quantities of ammonia, LPG, and amine and hydrogen sulfide are located. The full inspection report detailing the deficiencies can be found here.
As a result of the inspection, the EPA determined in November that the refinery could not resume operations without obtaining a new comprehensive PSD Permit, under the Clean Air Act. The new permit would require detailed air quality analyses and the use of the best available air pollution control technology.
In addition to the permit considerations, the EPA noted that it was continuing oversight of the facility, actively discussing the chemical safety issues with the company and determining next steps to address the issues.
The following month, under the consent order with the EPA, PHRT was instructed to remove all ammonia, liquified petroleum gas (or LPG), amines and hydrogen sulfide from the equipment at the facility. These chemicals had been used for refining processes.
Additionally, beginning immediately, the agreement required PHRT to take certain interim measures during the period before the materials were addressed, including increased monitoring and inspections of the systems containing the amine, ammonia and LPG, and actions to improve emergency preparedness.
The EPA reported that over 40,000 pounds of anhydrous ammonia was present at the refinery, with equipment containing over 37,000 pounds of LPG. The piping and many valves on the LPG unit were reportedly in an advanced state of corrosion and disrepair.
The legal agreement required the work to be performed by a qualified contractor to assess the systems containing anhydrous ammonia, LPG, amine and hydrogen sulfide and determine how to safely remove those chemicals. Once the contractor was approved by the EPA, they would have 30 days to perform an assessment of the three systems and propose options for the chemicals’ safe removal.
PHRT will now move all anhydrous ammonia, LPG and amine solutions that currently pose risks at the facility, with preparation work starting this month. Repairs to the ammonia system are reportedly scheduled to begin in early March, while chemical removal is scheduled to begin in early April to be completed by this summer.
According to the release, the EPA discussed, reviewed and approved the detailed plans for work associated with the agreement that will begin with removal of ammonia. All work will be overseen by the Agency and they will conduct around-the-clock air monitoring to ensure safety.
Contractors will reportedly remove the anhydrous ammonia by transferring the ammonia to specially designed shipping containers, then ship these containers off-island for sale or proper disposal. Any remaining ammonia vapors from the system will be purged and treated under closed conditions to prevent vapors from escaping.
After ammonia removal, the LPG will be transferred into shipping containers for shipment off-island for sale as usable product or for proper disposal, if necessary. Any remaining hydrocarbon vapors in the containers, as well as in process equipment and piping, will be depressurized and transferred into thermal oxidizer for destruction.
The contractors will then use nitrogen to remove any residual hydrocarbon vapors from the system, which will again be routed to the thermal oxidizer as part of the EPA’s approved plan.
Finally, to remove the amines, the amine liquid containing hydrogen sulfide will be transferred into appropriate shipping containers that will be shipped off-island for sale or proper disposal.
The EPA reports it has approved the plan to remove the amine liquid, on the condition that PHRT and its contractors accept EPA’s removal plan recommendations, make repairs to the system before beginning the work, and apply for and comply with necessary air permits from DPNR associated with the removal of the LPG.
The equipment will be chemically cleaned and rinsed once liquids have been transferred out of the units, purging all amine units with nitrogen gas until the system is free of all residual amine, hydrogen sulfide and hydrocarbon.