PORT HAMILTON REFINING AND TRANSPORTATION, LLLP

Port Hamilton Refining and Transportation, LLLP (PHRT) operates a single petroleum refining and bulk fuels storage complex at #1 Estate Hope, Christiansted, St. Croix, U.S. Virgin Islands, on the footprint of the former HOVENSA and Limetree Bay refinery. EPA ECHO records attribute eight quarters of noncompliance and approximately $2,150,000 in penalties over the trailing 24 months to the facility (EPA registry ID 110071301064), with zero active permits recorded as of a latest permit date of 2025-01-08 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The EJ index average reported in the ECHO export is 0.0. That number does not signal low community exposure — it signals absent data. EPA's EJSCREEN demographic layers for the U.S. Virgin Islands are not integrated into the standard ECHO export, so the underlying figure is structurally missing rather than measured.

Three events define the compliance record. On July 21, 2023, EPA issued Clean Water Act administrative orders jointly to PHRT and West Indies Petroleum Limited [source: https://www.epa.gov/system/files/documents/2023-08/PHRT%20and%20WIPL%20Clean%20Water%20Act%20Orders%20(July%2021%202023).pdf]. Four months later, on November 22, 2023, the U.S. Court of Appeals for the Third Circuit issued a precedential ruling addressing Clean Air Act Prevention of Significant Deterioration permitting for the refinery's restart [source: https://law.justia.com/cases/federal/appellate-courts/ca3/23-1094/23-1094-2023-11-22.html]. Separately, EPA Region 2 conducted and completed removal of ammonia, amines, and LPG from the idled plant [source: https://www.epa.gov/vi/refinery-st-croix-us-virgin-islands]. PHRT's public-facing materials describe the company as a renewable fuels hub [source: https://www.phrt.com/about], a positioning that sits against a record of regulatory orders and unresolved PSD permit status [source: https://www2.ca3.uscourts.gov/opinarch/231940p.pdf].

The St. Croix refinery's regulatory history predates PHRT by more than a decade. The site operated as HOVENSA until 2012, shutting down under Clean Air Act enforcement pressure and economic stress. Limetree Bay then acquired the asset and briefly restarted operations in February 2021, before a series of flaring events, oil-mist releases, and hydrogen sulfide incidents triggered EPA emergency orders and a second shutdown [source: https://www.virginislandsdailynews.com/news/port-hamilton-refining-issues-statement-on-refinery-ownership/article_8e318539-b00f-52ae-a848-6fdc05fda2a2.html]. PHRT, formed in 2022, acquired the Limetree Bay assets [source: https://www.phrt.com/about] and stepped into both the physical plant and an unresolved permitting posture that had accumulated across multiple ownership transitions.

The trailing 24-month window captured in the ECHO export (through 2026-05-04) runs along three intersecting regulatory tracks. First: on July 21, 2023, EPA issued administrative orders to PHRT and West Indies Petroleum Limited under the Clean Water Act, addressing conditions at the refinery and bulk fuels storage terminal at #1 Estate Hope [source: https://www.epa.gov/system/files/documents/2023-08/PHRT%20and%20WIPL%20Clean%20Water%20Act%20Orders%20(July%2021%202023).pdf]. Second: on November 22, 2023, the U.S. Court of Appeals for the Third Circuit issued a precedential decision in Port Hamilton Refining and Transportation LLLP v. EPA, No. 23-1094, addressing EPA's determination that the refinery required a Prevention of Significant Deterioration permit before it could resume operations [source: https://www2.ca3.uscourts.gov/opinarch/231940p.pdf] [source: https://law.justia.com/cases/federal/appellate-courts/ca3/23-1094/23-1094-2023-11-22.html]. Third: EPA Region 2 conducted and completed removal of ammonia, amines, and liquefied petroleum gas from the site under Superfund authority, an action documented on EPA's St. Croix refinery page [source: https://www.epa.gov/vi/refinery-st-croix-us-virgin-islands] and presented by On-Scene Coordinator Christopher Jimenez at the Caribbean Regional Response Team meeting in Rio Piedras, Puerto Rico, on January 23–25, 2024 [source: https://www.nrt.org/sites/172/files/EPA%20PHRT%20CRRT%20PPT%20Presentation%202-23-24.pdf].

At the territorial level, the U.S. Virgin Islands Department of Planning and Natural Resources Air Pollution Control Program issued permit STX-1-014-23, covering LPG operations at the Estate Hope facility, with Catherine Elizee identified as Environmental Manager [source: https://dpnr.vi.gov/wp-content/uploads/2023/05/05-PHRT-LPG-REVISED-afc.pdf]. On February 15, 2024, PHRT filed suit against Limetree Bay Terminals (doing business as Ocean Point Terminals) in the District of the Virgin Islands, docketed as 1:24-cv-00004 — a dispute over the shared terminal footprint that remained active as of October 3, 2024 [source: https://www.courtlistener.com/docket/68291068/port-hamilton-refining-and-transportation-lllp-v-limetree-bay-terminals/]. A separate proceeding, 1:24-cv-00023, appears in the U.S. Courts document repository [source: https://www.govinfo.gov/app/details/USCOURTS-vid-1_24-cv-00023/USCOURTS-vid-1_24-cv-00023-1]. One methodological note on the penalty figure: ECHO's eight-quarter noncompliance count and $2.15 million total are derived values. The exporter prorates a five-year penalty total to a 24-month window using the formula penalty_24mo = total_5yr × 24/60 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The headline dollar figure is therefore a derived estimate, not a single adjudicated fine.

Clean Water Act — July 21, 2023: EPA issued administrative orders to PHRT and co-owner West Indies Petroleum Limited addressing CWA violations at the #1 Estate Hope refinery and bulk fuels storage terminal. The orders trace the site's chain of custody from HOVENSA through Limetree Bay to the current ownership structure [source: https://www.epa.gov/system/files/documents/2023-08/PHRT%20and%20WIPL%20Clean%20Water%20Act%20Orders%20(July%2021%202023).pdf]. Clean Air Act / PSD — November 22, 2023: The Third Circuit ruled in Port Hamilton Refining and Transportation LLLP v. EPA, No. 23-1094, on EPA's position that a Prevention of Significant Deterioration permit was required before the refinery could resume operations. The court's opinion records that EPA notified PHRT by letter that it would need a PSD permit before restart could proceed [source: https://www2.ca3.uscourts.gov/opinarch/231940p.pdf] [source: https://digitalcommons.law.villanova.edu/thirdcircuit_2023/921]. CERCLA / CAA §112(r) removal — 2023–2024: EPA Region 2 completed removal of ammonia, amines, and LPG from the facility. OSC Christopher Jimenez presented the action at the Caribbean Regional Response Team meeting in Rio Piedras, Puerto Rico, on January 23–25, 2024, framing it under Section 112(r)(1) of the Clean Air Act Amendments of 1990 [source: https://www.nrt.org/sites/172/files/EPA%20PHRT%20CRRT%20PPT%20Presentation%202-23-24.pdf] [source: https://www.epa.gov/vi/refinery-st-croix-us-virgin-islands]. Territorial air permitting — May 2023: DPNR issued LPG permit STX-1-014-23 covering SIC 2911 operations at Estate Hope [source: https://dpnr.vi.gov/wp-content/uploads/2023/05/05-PHRT-LPG-REVISED-afc.pdf]. Civil litigation — February 15, 2024: PHRT v. Limetree Bay Terminals, 1:24-cv-00004 (D.V.I.), removed by defendant under 28 U.S.C., with last known docket activity on October 3, 2024 [source: https://www.courtlistener.com/docket/68291068/port-hamilton-refining-and-transportation-lllp-v-limetree-bay-terminals/]. Related proceeding 1:24-cv-00023 is on file with GovInfo [source: https://www.govinfo.gov/app/details/USCOURTS-vid-1_24-cv-00023/USCOURTS-vid-1_24-cv-00023-1]. The ECHO-reported aggregate penalty of approximately $2,150,000 over 24 months reflects a pro-rata derivation from the 60-month total rather than a single enforcement settlement [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Port Hamilton Refinery and Bulk Fuels Storage Terminal — #1 Estate Hope, Christiansted, St. Croix, USVI (EPA facility ID 110071301064). This is PHRT's only facility in the ECHO export. The site comprises a petroleum refinery (SIC 2911 / NAICS 324110) and an adjacent bulk fuels storage terminal, historically operated by HOVENSA and later by Limetree Bay [source: https://www.epa.gov/system/files/documents/2023-08/PHRT%20and%20WIPL%20Clean%20Water%20Act%20Orders%20(July%2021%202023).pdf]. ECHO attributes eight quarters of noncompliance and approximately $2.15 million in derived penalties to the site over 24 months, with zero active permits and a latest permit date of January 8, 2025 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. EPA Region 2 has documented completion of ammonia, amine, and LPG removal at the facility [source: https://www.epa.gov/vi/refinery-st-croix-us-virgin-islands]. The territorial air permit for LPG operations, STX-1-014-23, was issued by DPNR in May 2023 [source: https://dpnr.vi.gov/wp-content/uploads/2023/05/05-PHRT-LPG-REVISED-afc.pdf]. Surrounding communities on the south shore of St. Croix include Clifton Hill, Profit, and Estate Hope itself. EJSCREEN's standard national indices do not populate for USVI census geographies, which produces the 0.0 EJ index reading in the ECHO export. That figure should not be read as evidence of low community exposure — it is a data-coverage artifact, not a measurement.

Ammonia (NH3): EPA Region 2's removal action at the St. Croix refinery specifically targeted ammonia inventories stored on-site. Ammonia is regulated under Clean Air Act §112(r) as an extremely hazardous substance because of acute inhalation toxicity and the explosive and corrosive hazards it presents in concentrated storage [source: https://www.epa.gov/vi/refinery-st-croix-us-virgin-islands] [source: https://www.nrt.org/sites/172/files/EPA%20PHRT%20CRRT%20PPT%20Presentation%202-23-24.pdf]. The primary exposure pathway at Estate Hope is airborne release from tank or pipeline failure, with downwind residential receptors in south-shore Clifton Hill and Estate Hope. Amines: Process amines used in refinery gas treating — the stage that strips hydrogen sulfide and carbon dioxide from process streams — were also removed by EPA. Spent amine solutions carry H2S, mercaptans, and process residuals; a release creates both inhalation and surface-water contamination pathways [source: https://www.epa.gov/vi/refinery-st-croix-us-virgin-islands]. Liquefied petroleum gas (LPG): LPG inventory removal was conducted under the same EPA action and is separately the subject of DPNR air permit STX-1-014-23 [source: https://dpnr.vi.gov/wp-content/uploads/2023/05/05-PHRT-LPG-REVISED-afc.pdf]. LPG is flammable. At refinery scale, the primary hazard is vapor-cloud explosion and boiling-liquid expanding-vapor explosion (BLEVE) risk rather than chronic toxicity; §112(r) coverage reflects that catastrophic-release profile [source: https://www.nrt.org/sites/172/files/EPA%20PHRT%20CRRT%20PPT%20Presentation%202-23-24.pdf]. Because EJSCREEN demographic indices are not populated for USVI in the standard ECHO export, quantitative EJ-index comparisons with mainland refineries are unavailable. The qualitative picture — a single large industrial complex sitting adjacent to residential estates on a small island — is documented on EPA's St. Croix refinery page [source: https://www.epa.gov/vi/refinery-st-croix-us-virgin-islands].

Within the NAICS 324110/324199 peer set surfaced by ECHO, PHRT's eight quarters of noncompliance match EES Coke Battery and Artesia Refinery at the violation-frequency ceiling. Its derived 24-month penalty total of approximately $2.15 million, however, sits below all three peers: HollyFrontier El Dorado at $2.91 million, Artesia at $13.57 million, and EES Coke at $40.29 million [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. All four operators show zero active permits in the export and zero EJ index averages — the latter reflecting the ECHO exporter's derivation methodology rather than comparable community-exposure profiles across the four sites. On a dollars-per-violation basis, PHRT is the lowest-penalty member of the cohort. On a permit-status basis, the absence of active federal permits at a single-site operator that was the subject of a 2023 Third Circuit PSD decision is the feature that most distinguishes the PHRT row from its peers [source: https://law.justia.com/cases/federal/appellate-courts/ca3/23-1094/23-1094-2023-11-22.html].

PHRT is privately held and has no 10-K on file with the SEC; no Item 1A risk-factor disclosure is available in EDGAR for this entity (CIK: N/A). The closest analog to forward-looking risk disclosure in the record is the Third Circuit's opinion in No. 23-1094, which frames PSD permitting as a precondition to operation and identifies ongoing regulatory exposure to Clean Air Act New Source Review requirements [source: https://www2.ca3.uscourts.gov/opinarch/231940p.pdf] [source: https://law.justia.com/cases/federal/appellate-courts/ca3/23-1094/23-1094-2023-11-22.html]. The July 2023 CWA administrative orders remain the baseline compliance instrument for the site [source: https://www.epa.gov/system/files/documents/2023-08/PHRT%20and%20WIPL%20Clean%20Water%20Act%20Orders%20(July%2021%202023).pdf]. Together, those two instruments — one appellate, one administrative — define the regulatory ceiling under which any restart or expanded operation would have to proceed.