Energy Transfer Marketing & Terminals, L.P.

Energy Transfer Marketing & Terminals, L.P. (ETMT; formerly Sunoco Partners Marketing & Terminals, L.P. [SPMT]), processes, stores, and distributes natural gas liquids (NGLs) at its Marcus Hook Terminal (MHT; formerly Marcus Hook Industrial Complex [MHIC]) facility, which is located in Marcus Hook Borough, Delaware County.

Sunoco, Inc. (R&M), previously owned the facility and operated it as a petroleum refinery until 2011. SPMT acquired the idled petroleum refinery in early 2013 and redeveloped it into the MHIC, a NGLs hub on the U.S. East Coast. (On March 1, 2022, the company and facility names changed to ETMT and MHT, respectively.) ETMT receives NGL feedstock (i.e., ethane, propane, and butane) at the MHT facility via pipeline from the Marcellus Shale region, and processes, stores, and distributes the NGLs to local, regional, and international markets.

Currently Under Review

Plan Approval No. 23-0119K:

On February 14, 2022, ETMT submitted a Plan Approval application for a proposed expansion of the current ethane processing capacity at the MHT facility from 75,000 barrels per day (bpd) to 85,000 bpd. On March 1, 2022, ETMT submitted proofs of receipt for the notifications to the municipality and county made in accordance with 71 P.S. § 510 5 (Act 14 of 1984) and 25 Pa. Code § 127.43a. On March 9, 2022, ETMT submitted additional information pertaining to the design and plant layout of certain new equipment proposed to be installed as part of the expansion.

The current ethane process at the facility is comprised of the following steps:

• ETMT receives ethane feedstock via pipeline.
• An amine treatment system is used to remove carbon dioxide (CO2) from the ethane feedstock.
• A molecular sieve dehydration system is used to remove water from the ethane feedstock.
• A demethanizer is used to remove methane from the ethane feedstock, which is recovered and used in the MHT fuel gas system for the three existing auxiliary boilers at the facility.
• Three ethane chiller trains (in parallel), each consisting of a mixed refrigerant liquid (MRL) compressor and a heat exchanger, are used to chill the ethane product.
• The ethane product is/proposed to be routed to any of the refrigerated ethane product storage tanks at the facility (two existing, two to be installed under Plan Approval No. 23-0119J [PDF]) prior to distribution offsite.

The proposed ethane processing expansion includes the installation of the following equipment:

• A new (fourth) ethane chiller train, also including a MRL compressor and heat exchanger, in parallel with the three existing ethane chiller trains.
• A new boil off gas system for one of the refrigerated ethane product storage tanks to be installed under Plan Approval No. 23-0119J (PDF).
• New (additional) components for the feedstock metering, feedstock heating, amine treatment, and demethanizer off gas system.
• New piping, components (i.e., valves, pressure relief valves, pump and compressor seals, and flanges/connectors), and process vents.

Emissions from/relating to the proposed ethane processing expansion consist of the following:

• Fugitive volatile organic compound (VOC) and greenhouse gas (GHG) emissions from component leaks.
• Incremental carbon monoxide (CO); GHG; nitrogen oxides (NOx), including nitrogen dioxide (NO2); particulate matter (PM); sulfur oxides (SOx), including sulfur dioxide (SO2); and VOC emissions from the auxiliary boilers at the facility due to the associated steam demand.
• Incremental CO, GHG, NO2/NOx, PM, SO2/SOx, and VOC emissions from three existing flares at the facility due to the associated operational, maintenance, and emergency flows from process vents.

CO, GHG, NOx, PM, SO2, and VOC emissions from the proposed ethane processing expansion itself do not trigger any significant permitting requirements. However, after accounting for all emissions increases and decreases from all NGL-related projects at the MHT as a single aggregated project in accordance with a January 9, 2019, adjudication by the Environmental Hearing Board (EHB), the proposed ethane processing expansion triggers federal Prevention of Significant Deterioration of Air Quality (PSD) requirements for CO, GHG, and NO2 (pollutants for which Delaware County is in attainment of the National Ambient Air Quality Standards [NAAQS]), as well as New Source Review (NSR) requirements for NOx and VOCs (precursors of ozone, for which Delaware County is not in attainment of the NAAQS).

DEP has reviewed the Plan Approval application and has determined it to contain all necessary information to meet the completeness requirements of federal and DEP’s regulations. Per its regulatory duty, DEP will now conduct a technical review of the Plan Approval application, found below:

• February 14, 2022, ETMT Plan Approval Application No. 23-0119K [non-confidential version] (PDF)
• March 1, 2022, proofs of receipt for municipal and county notifications (PDF)
• March 4, 2022, DEP Air Quality Modeling Section Administrative Completeness Memo (PDF)
• March 15, 2022, DEP Administrative Completeness Letter (PDF)
• March 19, 2022, Pa. Bulletin Notice of Receipt of Plan Approval Application No. 23-0119Ksee page 1658

The public will be invited to participate in this process through a public comment period and virtual public hearing. More information on those opportunities will be posted here once available. Because the facility is located in an Environmental Justice (EJ) area, DEP will follow its EJ Enhanced Public Participation Policy.

• DEP hosted an informational meeting on June 8, 2022 at 6 PM at the Marcus Hook Municipal Building, 1111 Market St, Marcus Hook, PA, 19061. DEP invited representatives from ETMT to explain the proposed ethane processing expansion and both groups answered related questions from the public.
  • DEP’s Plain Language Summary, Spring 2022
  • DEP’s Presentation – June 8, 2022
  • ETMT’s Plain Language Summary, Spring 2022
  • ETMT’s Presentation – June 8, 2022

DEP Issued Permits and Plan Approvals

The MHT facility is currently permitted under Title V Operating Permit (TVOP) No. 23-00119 and Plan Approval Nos. 23-0119E [revised] and 23-0119J:

• A Plan Approval is required for the construction, shakedown, and/or performance testing of most projects that take place at this facility, while the TVOP is required for the continued operation of the air emission sources at a major facility.
• The TVOP consolidates applicable regulations and Plan Approvals into one document and does not adopt any new regulations.

Current TVOP

On August 25, 2020, DEP modified TVOP No. 23-00119 to change an existing deethanizer at the facility to a demethanizer. The Minor Operating Permit Modification resulted in minor emissions increases of previously-emitted air contaminants.

• Modified TVOP, August 25, 2020 (PDF)
• Technical Review Memo, August 12, 2020 (PDF)
• Minor Operating Permit Modification Application, March 20, 2020 (PDF)

Current Plan Approvals

On February 12, 2021, DEP issued Plan Approval Nos. 23-0119E [revised] and 23-0119J, as follows:

• Revised Plan Approval No. 23-0119E to address the EHB’s January 9, 2019, adjudication that DEP reevaluate all NGL-related projects at the MHT as a single aggregated project to determine the applicability of federal PSD and/or NSR requirements. Revised Plan Approval No. 23-0119E incorporates the requirements of previously-unincorporated Plan Approval Nos. 23-0119D and (the original) 23-0119E.
  • Plan Approval Issuance, February 12, 2021 (PDF)
  • Plan Approval Technical Review Memo, February 5, 2021 (PDF)
  • Plan Approval Application, July 29, 2019 (PDF)


• Plan Approval No. 23-0119J for the installation of the following sources and equipment under “Project Phoenix”:
  • Two new 600,000-bbl refrigerated ethane storage tanks;
  • One new amine treatment system;
  • One new dehydration train system;
  • Two new refrigeration systems;
  • Two new demethanizers;
  • Two new wet surface air cooling (WSAC) systems;
  • One new elevated, air-assisted Cold Flare; and
  • Various piping connections and components.
  
  
  • Plan Approval Issuance, February 12, 2021 (PDF)
  • Plan Approval Technical Review Memo, February 5, 2021 (PDF)
  • Plan Approval Application, July 28, 2019 (PDF)

The responses to the comments received from the public and the company concerning both plan approvals are below:

• Comment/Response Document to Public Comments (PDF)
• Comment/Response Document to Company’s Comments (PDF)