Which Were the Regulatory Review of the Deal of Sunoco and Etp
Judge Bernard A. Labuskes, Jr., of the Environmental Hearing Board (EHB), recently ruled that a serial of Sunoco projects at Marcus Hook, which the company said were all independent, were really all part of one projection.
Considering them as a unmarried project is critical. By proposing them individually, Sunoco has been able to avoid any consideration of the overall effect of the facility on air pollution. Each small pace has been safely below the regulatory limits. At present, the judge is maxim, the facility as a whole must meet pollution regulations.
Some of the details of the judge's ruling are here, and the complete ruling is hither. The immediate practical importance of the ruling is that the Pennsylvania Department of Environmental Protection (DEP) must now re-evaluate the set of projects to meet if the resulting overall petrochemical complex violates ecology regulations. I look frontwards to the results of that review.
Interesting details about NGL processing at Marcus Claw. In the meantime, the ruling contains a great deal of information that I found fascinating (and that I promise will interest others) about what Sunoco has been doing at Marcus Claw. Merely much of the information is not very accessible because of the dry and technical nature of the 78-folio ruling. I have tried to summarize information technology in an easier-to-digest course below.
The ruling dealt with vi "projects". Afterwards in this post, there are diagrams of five of them. (The i I didn't diagram, "Project B", is not closely related to the others.) The diagrams show the office each project plays in the processing of "natural gas liquids" (NGLs) at Marcus Hook.
Here is a listing of the five related projects:
- Project 1: new storage tanks for ethane and propane
- Project A: a system to treat and separate mixtures of ethane and propane
- Project C: a chilling belfry to generate cooling h2o, to supplant an air chiller for ethane and propane
- Project D: additional storage tanks for ethane and propane
- Project E: a organisation to excerpt butane and heavier hydrocarbons from NGL mixtures
Simply from that list, you can encounter that it is hard for Sunoco to defend the "independence" of these projects. The judge found that the connections amongst them and their introduction in quick succession betoken an overall program, not "independent projects". That finding is reinforced by their physical proximity and connecting pipes. (This is illustrated in the aeriform photo near the finish of this blog mail.)
Getting deeper into the weeds. There's a lot of detail provided in the judge's finding, and the most important parts are covered in the balance of this post. The post contains some technical terms that may not exist familiar, and then I'll summarize them here.
- Amine treatment: removes acidic gases (primarily hydrogen sulfide) from NGLs
- Aridity system: removes water vapor from NGLs
- Deethanizer: extracts the ethane from a mixture of NGLs
- Depropanizer: extracts the propane from a mixture of NGLs
- Debutanizer: extracts the butane from a mixture of NGLs
- Fractionation towers: a full general term that includes deethanizers, depropanizers, and debutanizers as well equally towers for other refinery processes
In the diagrams below, I have shown in blood-red the parts that are added or changed past that item project. I take also noted dates of submission and approval, which add to the impression that this was a planned sequence, not contained projects. I created this set of diagrams by simplifying and combining some of the diagrams and data in the ruling.
Some readers who are more familiar with petrochemical processing than I am will probably detect errors or inconsistencies. I hope they will submit comments with suggestions and corrections.
Project 1. Approved February 5, 2013. The plan approval authorized the facility to receive liquefied ethane or propane via pipeline, and to store these in cryogenic storage tanks. Periodically, these liquids would exist loaded on ships and sent "off site".
Project A. Submitted March 4, 2013 (almost a month later Projection one was canonical). Sunoco requested approving to install a deethanizer unit, amine treatment organisation, and dehydration organisation. These facilities meant that Sunoco could accept a mixture of ethane and propane at Marcus Claw, treat it, and separate it into marketable products. Projection A was approved on September 5, 2013. It is shown in the diagram below, with the changes from Project 1 shown in scarlet.
Project B. Submitted September 13, 2013 (less than two weeks after Project A was approved). Project B was approved January twenty, 2014. This project, non as closely related as the others, was to accept tank trucks carrying heavier hydrocarbons that didn't demand pinch ("natural gasoline"), with equipment to separate these into salable products (pentane and light naphtha). The light naphtha would go out Marcus Claw past pipeline or ship; the pentane would be added to existing pentane storage and and so transported by truck or send. The master elements in common with the other projects are storage and send-loading equipment.
I did not create a diagram for Project B.
Projection C. Submitted April 7, 2022 (while Project B was still under review). Approved November nineteen, 2014. This project involved adding a cooling tower to provide cooling water, to supervene upon the air chiller of Project A.
Project D. Submitted September 26, 2022 (even earlier approvals for projects B and C were issued). Approved Feb 26, 2015. This projection was primarily to increase storage for separated ethane, propane, and butane, prior to shipment.
Projection Due east. Submitted September xvi, 2015. Approved Apr one, 2016. This projection involved two depropanizer fractionation towers, and a debutanizer fractionation tower, as well as other components. With these additions, Sunoco could process mixed NGLs, received from western Pennsylvania, into their component gases for storage and shipment. It used existing storage for all of these.
Every bit an aside, the Marcus Hook facility spans the border of Pennsylvania and Delaware. Several of the "projects" involved in this case were supposed make use of an existing flare on the Delaware side of the line. Merely the Delaware Department of Natural Resources and Environmental Control found, in March of 2017, that only materials originating in Delaware could be flared at that place. That ruling happened after the submissions and approvals listed above. At the time, Sunoco was fined $750,000 for flaring in Delaware materials that originated in Pennsylvania.
There is no indication in the EHB ruling that the Delaware determination was discussed in this example. Simply tin can Sunoco move alee with plans that violate the 2022 Delaware conclusion? If not, must the project plans involving that Delaware flare be revised and re-submitted for approval using a Pennsylvania-based flare? The EHB ruling doesn't provide any enlightenment about this.
Looking at the diagrams of the progression from two storage tanks in Project 1 to the full NGL processing plant in Project E, it is like shooting fish in a barrel to meet why the judge decided that all of them should take been considered equally a unmarried projection. The quick succession with which each new "project" was submitted immediately later on (or even prior to) the approval of its predecessor likewise suggests a planned progression, not a series of standalone decisions.
How the Marcus Hook institute is laid out. Some other piece of testify that convinced the judge that all these projects should be combined for regulatory purposes was the layout at Marcus Hook. If the projects were really contained, their components wouldn't be intermingled and connected to each other past pipes. But that is exactly the situation at Marcus Hook. Here is a diagram showing what is where, superimposed on a Google Maps image. I created it by using information from the EHB ruling to identify the diverse pieces of equipment.
Autonomously from the obvious clustering and pipage connections amid the components of the diverse projects, the other characteristic that jumps out from this image is the availability of a lot of relatively unused space at the upper right and lower left in the diagram. We hear that Sunoco has much bigger plans for Marcus Hook in the future, and clearly they have space bachelor.
What I promise this blog post illustrates is that the judge used nil more than mutual sense in ruling that these are all parts of one project. This seems so obvious that it makes me wonder most the DEP staffer(southward) who approved each of them as independent projects. What were they thinking? Are they competent to do their jobs? Was Sunoco able to pressure level them in an inappropriate way? The DEP has some explaining to do.
What happens at present? No information is available about the timetable for future steps regarding regulatory action at Marcus Hook. The guess sent the combined project back to the DEP for re-evaluation, but we don't know how long that re-evaluation will have or even whether it volition really occur. At that place are apparently several directions this could accept.
For instance, the DEP could review the combined project and determine that, even with all the projects considered together, it does not violate whatsoever regulations. That is what Sunoco and the DEP claimed in this case, and what the Clean Air Quango (the plaintiff) takes effect with. If that is the DEP'southward decision, Sunoco would be free to continue with its plans, and might even be able to go on submitting new "contained projects" and getting them approved every bit such.
Alternatively, the DEP could make up one's mind that the combined project violated environmental regulations and Sunoco would have to make changes to bring the plant into compliance. That could add months or years to the construction procedure.
Or, either the DEP or Sunoco could claiming the Environmental Hearing Board in court, claiming that the ruling was in error and that the projects were indeed independent.
No matter what management the case takes, Sunoco is gratuitous (for the moment) to pursue its plans. The judge found that, although the regulatory procedure was flawed, it was not clear that people would really be harmed if work were immune to continue. In the absence of that kind of testify, he is permitting Sunoco to implement its "projects".
Source: https://dragonpipediary.com/2019/01/15/whats-sunoco-been-doing-at-marcus-hook/
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