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]), 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

Significant Modification to Title V Operating Permit (TVOP) No. 23-00119:

On November 12, 2022, the Environmental Quality Board amended 25 Pa. Code Chapter 129 (relating to standards for sources) of its statutes to establish additional reasonably available control technology (RACT) requirements and RACT emission limitations for certain major stationary sources of oxides of nitrogen [NOx] and volatile organic compound (VOC) emissions in existence on or before August 3, 2018, to address the Federal requirements for the 2015 8-hour ozone National Ambient Air Quality Standards (NAAQS) under the Clean Air Act (CAA). This final-form rulemaking, also referred to as RACT III, established 25 Pa. Code §§ 129.111–129.115 (relating to additional RACT requirements for major sources of NOx and VOCs for the 2015 ozone NAAQS) to meet CAA requirements for the control of ground-level ozone, and applies to the owners and operators of all facilities in Pennsylvania that emit or have a potential to emit greater than 100 tons per year of NOx and/or 50 tons per year of VOCs. Emissions of NOx and VOCs are precursors to ground-level ozone formation. Ground-level ozone, a public health and welfare hazard, is not emitted directly to the atmosphere from air contamination sources, but forms from the photochemical reaction between emissions of NOx and VOCs in the presence of sunlight.

On December 20, 2022, the Department of Environmental Protection (DEP) received a significant modification application for TVOP No. 23-00119 from ETMT, along with a RACT III alternative compliance plan for the MHT. The RACT III alternative compliance plan does not adopt any new regulations. If approved by DEP, the RACT III alternative compliance plan will be submitted to the United States Environmental Protection Agency (EPA) as a revision to the Commonwealth’s State Implementation Plan (SIP). Requirements that are not part of the RACT III alternative compliance plan will be excluded from the SIP revision submittal.

The following is a summary of the RACT III alternative compliance requirements for this facility that are proposed to be submitted to EPA as a revision to the Commonwealth’s SIP, found in the TVOP:

LDAR = Leak Detection and Repair

Plan Approval No. 23-0119K:

On February 14, 2022, ETMT submitted a Plan Approval application to expand the ethane chilling capacity at the MHT from approximately 75,000 barrels per day (bpd) to approximately 85,000 bpd. On March 9, 2022, DEP considered the application to be administratively complete.

The facility is located in an Environmental Justice (EJ) area; therefore, DEP is following its EJ Enhanced Public Participation Policy. [Note: While DEP adopted an interim final EJ Policy on September 16, 2023, the 2004 Environmental Justice Public Participation Policy applies to applications received before that date.] Below is a link to a plain language summary for the Plan Approval application:

• DEP’s Plain Language Summary, August 2023 (PDF)

The general ethane chilling process at the MHT consists of the following steps (in order):

• The delivery of ethane feedstock to the MHT via pipeline.
• The metering, heating, and filtering of the ethane feedstock prior to any processing.
• The removal of carbon dioxide [CO₂] from the ethane feedstock via an amine treatment system.
• The removal of sulfur from the ethane feedstock via sulfur treat beds.
• The removal of water from the ethane feedstock via molecular sieve desiccant dehydrators.
• Additional filtering of the ethane feedstock to remove any entrained desiccant beads from the dehydrators.
• The removal of methane [CH₄] from dry ethane via the existing demethanizer at the MHT. The methane off-gas from the demethanizer is pulled to the fuel gas system, proceeds to the existing 15-2B gas plant, and is ultimately consumed by the auxiliary boilers.
• The chilling of treated, dry ethane via any of the chiller trains.
• The routing of refrigerated ethane to any of the two existing refrigerated ethane product storage tanks at the MHT and/or the two refrigerated ethane product storage tanks authorized under Plan Approval No. 23-0119J (PDF). The boil-off gas (BOG) from the refrigerated ethane product storage tanks is also pulled to the fuel gas system to be consumed by the auxiliary boilers.
• The transfer of refrigerated ethane offsite via the existing marine vessel loading (refrigerated).

ETMT has proposed the following to accommodate the expansion (collectively referred to as the “Ethane Chilling Expansion Project”):

• The installation of the following ethane chilling process equipment:
• A new (fourth) ethane chiller train, consisting of a mixed refrigerant liquid compressor and heat exchanger, ethane chiller, and related equipment, in parallel with the three existing ethane chiller trains at the MHT.
• A new BOG system, consisting of a compressor, chiller, and related equipment.
• New piping, fugitive emissions components, and process vents associated with the new ethane chiller train and BOG system.
• Updated piping and fugitive emissions components for certain existing ethane chilling process equipment (i.e., the feed metering, feed heating, amine treatment, and demethanizer off-gas systems) at the MHT.
• Operational, maintenance, and emergency connections from the new ethane chiller train to the existing West Cold Flare at the MHT.
• Operational, maintenance, and emergency connections from the new BOG system to the Project Phoenix Cold Flare authorized under Plan Approval No. 23-0119J [PDF]).
• Additional steam demand on the three existing auxiliary boilers at the MHT by certain existing ethane chilling process equipment (i.e., the dehydrators and water/ethylene glycol system utility) at the MHT, as well as for maintenance purposes, to support the additional ethane throughput through new and existing ethane chilling process equipment.

Emissions from/relating to the proposed Ethane Chilling Expansion Project consist of the following:

• Fugitive VOC and greenhouse gas (GHG) emissions from component leaks.
• Incremental carbon monoxide [CO], GHG, NO_x, sulfur dioxide [SO₂], and VOC emissions associated with the proposed process vent connections to the West Cold Flare and Project Phoenix Cold Flare.
• Incremental CO; GHG; lead [Pb], NO_x, particulate matter (PM), PM less than 10 µm in aerodynamic diameter [PM₁₀], PM less than 2.5 µm in aerodynamic diameter [PM_2.5], SO₂, and sulfuric acid mist [H₂SO₄] emissions associated with the proposed steam demand on the auxiliary boilers.

CO, GHG, H₂SO₄, NO_x, Pb, PM, PM₁₀, PM_2.5, SO₂, and VOC emissions from the proposed Ethane Chilling Expansion Project 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, the proposed Ethane Chilling Expansion Project triggers federal Prevention of Significant Deterioration of Air Quality (PSD) requirements for CO, GHGs, NO_x, and PM_2.5 (pollutants for which Delaware County is designated as attainment of the NAAQS), as well as Nonattainment New Source Review (NSR) requirements for NO_x and VOCs (precursors to ozone, for which Delaware County is designated as nonattainment of the NAAQS).

Public Participation

DEP previously hosted an informational meeting on June 8, 2022, in Marcus Hook Borough. DEP invited representatives from ETMT to explain the ethane processing expansion project proposed in its application for Plan Approval No. 23-0119K, and both groups answered related questions from the public. Below are links to information associated with the informational meeting:

• DEP’s Plain Language Summary, Spring 2022 (PDF)
• DEP’s Presentation – June 8, 2022 (PDF)
• ETMT’s Plain Language Summary, Spring 2022 (PDF)
• ETMT’s Presentation – June 8, 2022 (PDF)

On August 5, 2023, DEP published a notice of intent to issue Plan Approval No. 23-0119K in the Pennsylvania Bulletin (PDF, see pages 4456–4458) and initiated a public comment period. On August 7–9, 2023, ETMT published a notice of DEP’s intent to issue Plan Approval No. 23-0119K in the Delaware County Daily Times (PDF).

On September 19, 2023, DEP held a combined public meeting and hearing regarding Plan Approval No. 23-0119K in Boothwyn, PA (PDF). During the public meeting, representatives from ETMT and DEP provided a brief explanation of the proposed ethane processing expansion project and permitting process, respectively, and answered associated questions from the public. Following the meeting, DEP held the public hearing to receive oral and written testimony regarding DEP’s intent to issue Plan Approval No. 23-0119K.

The public comment period for Plan Approval No. 23-0119K closed on September 29, 2023. DEP is currently considering all comments received during the public comment period and will address these before taking any action on the Plan Approval application.

On October 14, 2023, DEP published a notice of intent to issue the significant modification to TVOP No. 23-00119 in the Pennsylvania Bulletin (PDF, see pages 6496–6498) and initiated a public comment period. On October 17–19, 2023, ETMT published a notice of DEP’s intent to issue the significant modification to TVOP No. 23-00119 in the Delaware County Daily Times (PDF).

The proposed TVOP is currently open for public comment. Comments may be made in writing to Mr. James Rebarchak, Environmental Program Manager, DEP Southeast Regional Office (SERO), 2 East Main Street, Norristown, PA 19401, or electronically at ra-epseroaqpubcom@pa.gov.

On November 14, 2023, DEP will hold a public hearing at the Marcus Hook Municipal Building, 1111 Market Street, Marcus Hook, PA 19061, from 6:00 PM–7:00 PM. The public hearing will be held to accept oral and written testimony on the proposed RACT III alternative compliance plan action and the proposed revision to the Commonwealth’s State Implementation Plan. The public comment period will remain open through November 24, 2023, after which DEP will consider and address all comments received and take final action on the significant modification application.

Marcus Hook Public Hearing Flyer (PDF)

Application and Associated Documents for Plan Approval No. 23-0119K

• 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. 23-0119K (PDF, see page 1658)
• August 12, 2022, DEP Air Quality Modeling Section Comments on PSD Air Quality Analyses (PDF)
• February 27, 2023, ETMT Responses to DEP Air Quality Modeling Section Comments & Revised Air Quality Modeling Report (Appendix F of Plan Approval Application No. 23-0119K) (PDF)
• March 31, 2023, Addendum to Plan Approval Application No. 23-0119K (PDF)
• April 3, 2023, Additional Information Requested by DEP for Plan Approval Application No. 23-0119K (PDF)
• Draft Plan Approval No. 23-0119K (PDF)
• August 4, 2023, Draft Technical Review Memo Associated with Draft Plan Approval No. 23-0119K (PDF)
• September 19, 2023, Public Hearing Transcript (PDF)
• Written Public Comments Received (PDF)

Significant Modification Application and Associated Documents for TVOP No. 23-00119

• December 20, 2022, ETMT Significant TVOP Modification Application (PDF)
• Draft Significant Modification to TVOP No. 23-00119 (PDF)
• October 13, 2023, Draft Technical Review Memo Associated with Significant Modification to TVOP No. 23-00119 (PDF)