BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Equistar Chemicals, L.P.
Line 6 Suizer Compressor Upgrade; Tank Car
Aromatics Loading;
LLDPE Flare Meter; PP Flare
Meter; Ethylene Unit Analyzer; Particulate Emission
Reduction Project; Parallel Flare Vaporizer; LDPE
Compressor Shutdown Improvements; Lines 3
& 4
Hyper Suction GC Analyzer;
Off-Gas Tie Ins; EP
Capacity Increase; H2/C2 Analyzer; Ethylene Unit
Flare Meter; EP Analyzer Replacement, and; PP
Flare Monitor
Property Identification Number
110-032-1141
TO:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State ofIllinois Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
Steve Santarelli
Illinois
Department ofRevenue
101
West Jefferson
P.O. Box 19033
Springfield, Illinois
62794
NOTICE
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
PCB
(Tax Certification)
W.S. Westlake
do Tax Dept.
Equistar Chemicals, L.P.
One Houston Center
1221 McKinney St.
Houston, Texas 77253-3646
PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution Control
Board
the
APPEARANCE
AND
RECOMMENDATION
of
the
Illinois
Environmental
Protection Agency, a copy ofwhich is herewith served upon you.
Date:
October
15,
2003
Robb
H. Layman
Special Assistant Attorney General
ARDC
#6205498
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 North Grand Avenue East
P.O. Box
19276
Springfield, IL 62794-9276
Telephone: 217/782-5544
Facsimile:
217/782-9807
THIS FILING IS SUBMITTED
TDD:
217/782-9143
ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Equistar Chemicals, L.P.
)
Line 6 Sulzer CompressorUpgrade; Tank Car
)
Aromatics Loading; LLDPE Flare Meter; PP Flare
)
Meter; Ethylene Unit Analyzer; Particulate Emission
)
Reduction Project; Parallel Flare Vaporizer; LDPE
)
Compressor ShutdownImprovements; Lines 3
& 4
)
Hyper Suction GC Analyzer;
Off-Gas Tie Ins; EP
)
Capacity Increase; H2/C2 Analyzer; Ethylene Unit
)
Flare Meter; EP Analyzer Replacement, and; PP
)
Flare Monitor
)
PCB
Property Identification Number
)
(Tax Certification)
110-032-1141
)
)
APPEARANCE
I hereby file my Appearance
in this
proceeding
on behalf ofthe Illinois Environmental
Protection Agency.
.
Robb H. Layman.
Special Assistant Attorney General
ARDC#6205498
DATED:
October
15,
2003
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021
North Grand Avenue East
P.O.Box
19276
Springfield, Illinois
62794-9276
Telephone: 217/782-5544
Facsimile:
217/782-9807
.
THIS FILING IS SUBMITTED
TDD:
.
217/782-9143
ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Equistar Chemicals, L.P.
)
Line 6 Suizer Compressor Upgrade; Tank Car
)
Aromatics Loading; LLDPE Flare Meter; PP Flare
)
Meter; Ethylene Unit Analyzer; Particulate Emission
)
Reduction Project;
Parallel Flare Vaporizer; LDPE
)
Compressor Shutdown Improvements; Lines 3
& 4
)
Hyper Suction GC Analyzer; Off-Gas Tie Ins; EP
)
Capacity Increase; H2/C2 Analyzer; Ethylene Unit
)
Flare Meter; EP Analyzer Replacement, and; PP
)
Flare Monitor
.
)
PCB
Property IdentificationNumber
)
(Tax Certification)
110-032-1 141
)
)
RECOMMENDATION
Now Comes the Illinois Environmental Protection Agency (“Illinois EPA”), through its
attorneys, and pursuant to Section 125.204 ofthe Illinois Pollution Control Board’s (“Board”)
regulations, files the following Recommendation regardingthe tax certification of air pollution
control facilities pursuant to 35 Ill. Adm.
Code
125.204.
1)
On December 31, 2002, the Illinois
EPA received fifteen
(15)
requests from Equistar
Chemicals, L.P.
for Illinois EPA recommendations regarding the tax certification ofair
pollution control facilities pursuant to 35 Ill. Adm. Code
125.204, and noted the request
as log numbers TC-02-12-3 1 -E; TC-02- 12-31-F; TC-02- 12-31-G; TC-02-12-3 1-H; TC-
02-12-31-I; TC-02-12-3 1-J; TC-02-12-3 1-K; TC-02-12-3 1-L; TC-02-l2-3 1 -M; TC-02-
12-31-0;
TC-02-12-3 1 -P;
TC-02-12-3 1-Q; TC-02-12-3 1 -R; TC-02-12-3 1-S, and; TC-02-
12-31-T. (Exhibit A)
The applicant’s address is:
W.S. Westlake
do Tax Dept.
Equistar Chemicals, L.P.
One Houston Center
1221 McKinney St.
Houston, Texas 77253-3646
2)
The air pollution control facilities in this request are located at 8805 N. Tabler Road,
Morris
and consist ofthe following:
A)
Line 6 Sulzer Compressor Upgrade which reduces excess emissions.
Because the primary purpose ofthis system is to reduce or eliminate air
pollution, it is certified as a pollution control facility.
B)
Tank Car Aromatics Loading for debutanized concentrate product into rail
cars.
Volatile organic emissions from the rail car transfer system will be
vented to an existing flare which will result in reduced emissions.
Because the primarypurpose ofthis
system is to reduce or eliminate air
pollution, it is certified as a pollution control facility.
C)
Linear LowDensity Polyethylene Plant (LLDPE) Flare Meter which
measures the amount ofpollutants going to the control device (flare) in
conjunction with the control efficiency ofthe flare.
Because the primary
purpose ofthis system is to reduce or eliminate air pollution, it is certified
as a pollution control facility.
D)
Polypropylene Plant (PP) Flare Meter which measures the amount of
pollutants going to the control device (flare) in conjunction with the
control efficiency ofthe flare.
Because the primary purpose ofthis system
is to reduce or eliminate air pollution, it is certified as a pollution control
facility.
E)
Ethylene Unit Analyser Vent which measures the amount ofpollutants
being vented.
Because the primary purpose of this system is to reduce or
eliminate airpollution, it is certified as a pollution control facility.
F)
Particulate Emission Reduction Project which allows gas to be vented to
the flare thereby reducing volatile organic compound (VOC) and
particulate emissions.
Because the primary purpose of this system is to
reduce or eliminate airpollution, it is certified as a pollution control
facility.
G)
Parallel Flare Vaporizer which eliminated flaring and as a result reduced
emissions.
Because theprimary purpose ofthis system is to reduce or
eliminate air pollution, it is certified as a pollution control facility.
H)
Low Density Polyethylene Plant (LDPE) Compressor Shutdown
Improvements which reduces emissions due to reduced venting.
Because
the primary purpose of this system is to reduce or eliminate air pollution, it
is certified as a pollution control facility.
I)
Lines 3
& 4 Hyper Suction GC analyzer which reduces excess emissions
due to reduced venting.
Because the primary purpose ofthis system is to
reduce or eliminate air pollution, it is certified as a pollution control
facility.
J)
Off-Gas Tie Ins which reduces VOC emissions.
Because the primary
purpose ofthis system is to reduce or eliminate air pollution, it is
certified
as a pollution control facility.
K)
EP capacity increases which reduce excess emissions.
Because the
primarypurpose ofthis system is to reduce or eliminate air pollution, it is
certified as a pollution control facility.
L)
H2/C2 Analyzer which reduces VOC emissions and improves process
control and reliability.
Because the primary purpose of this system is to
reduce or eliminate air pollution, it is certified as a pollution control
facility.
M)
Ethylene Unit Flare Metering which reduces emissions at flare.
Because
the primarypurpose of this system is to reduce or eliminate air pollution, it
is certified as a pollution control facility.
N)
EP Analyzer replacement which reduces VOC emissions.
Because the
primary purpose ofthis system is to reduce or eliminate airpollution, it is
certified as a pollution control facility.
0)
Polypropylene Plant (PP) flare monitor which assures smokeless flare
operation from reduced steam consumption which reduces excess
emissions.
Because the primary purpose ofthis system is to reduce or
eliminate air pollution, it is
certified as a pollution control facility.
4.
Section
11-10 of the Property Tax Code, 35 ILCS 200/11-10
(2000), defmes “pollution
control facilities” as: “any system, method, construction, device
or appliance appurtenant
thereto or any portion ofany building or equipment, that is designed, constructed,
installed or operated for the primary purpose of:
(a) eliminating, preventing, or reducing
air or waterpollution
.
.
.
or (b) treating, pretreating, modifying or disposing ofany
potential solid, liquid or gaseous pollutant which ifreleased without treatment,
pretreatment modification or disposal might be harmful, detrimental or offensive to
human, plant or animal life, or to property.”
5.
Pollution control facilities are entitled to preferential tax treatment, 35 ILCS 200/11-5
(2000).
6.
Based on the information in the application and the purpose ofthe facilities, to prevent,
eliminate or reduce air pollution, it is the Illinois EPA’s
engineeringjudgment that the
described facilities may be considered “pollution control facilities,” pursuant to 35 Ill.
Adm. Code 125.200(a), with the primary purpose ofeliminating, preventing, or reducing
air pollution, or as otherwise provided in 35
Ill. Adm.
Code 125.200.
Therefore, the
facilities are eligible for tax certificationfrom the Board.
7.
Therefore, the Illinois EPA recommends that the Board issue the requested tax
certifications.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
By:
_____________________
R6bb H. Layman
Special Assistant Attorney General
Of Counsel:
Charles E. Matoesian
Assistant Counsel
October
15,
2003
1021
North Grand Ave. E.
P.O. Box 19276
Springfield,
Illinois 62794-9276
Telephone:
217/782-5544
Facsimile:
217/782-9807
TDD:
217/782-9143
CUMMINGS
WESTLAKE
LP
INDUSTRIAL
PROPERTY
TAX
SOLUTIONS
FACSIMILE
TRANSMITTAL
SHEET
TO:
FROM:
Mr. Floyd McKinney
WendellWestlake
COMPANY:
DATE:
IL EPA
12/30/02
,
FAX NUMBER:
TOTAL
NO. OF
PAGES INCLUDING COVER:
217-524-5023
.
-PI-~ONE
NUMBER:
SENDER’S
REFERENCE NUMBER:
217-782-7187
n/a
RE:-
-
Equistar Chemicals, LP
—
Aix and WaterApplications for Certification
(Property Tax
Treatment)
.
E~1~GENT
0
FOR REVIEW
0
PLEASE COMMENT
0
PLEASE
REPLY
0
PLEASE
RECYCLE
NOTES/COMMENTS:
Floyd,
Thanks
again for your guidance
on
these
applications.
I
appreciate your
checking into the due
.-~
date for these applications and while I understand that your folks are saying that April
15th
is the
due date, I would like to file these now (before year-end) to be
safe.
Will forward the hard
copies
to you
as well.
Please review these whenyou getback in and if
you need
additional information,
please let me know.
Regards,
Wendell
I-
RECEfVED
D~C
3
12002
I~A DAPC
-
11000
Richmond
Ave.,
Ste.650
Houston,
Texas
77042
PH:
713-266-4456
FAX:
713-266-2333
APPLICATION FOR CERTIFICATION
(PROPERTY
TAX
TREATMENT)
~s
Agency
is
authorized
to
request
is
POLLUTION CONTROL
FACILITY
information under Illinois Revised Statues,
1979,
AI~,~’
WATER
0
Chapter,
120,
Section
502a-5,
Disclosure ofthis
information
is
voluntaiy.
However,
failure
to
ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
comply
could
prevent
your
application
from
P.
0.
Box 19276, Springfield.
IL
62794.9276
being processed or
could
result
in
denial of
your
application for
certification.
FOR AGENCY USE
File No.
—
Date
Received
Certification
No.
Date
C.)
a:
I,.
Company Name
g~e~r~?
ccJ~.L~,
L-P
Person Authorized to Receive Certification
Person to Contact for Additional Details
Street Address
Street Address
~T.1O~us~xo~
~
tzLt
~
~4unicipaIity,
State& Zip Code
Municipality, State & Zip Code
-~
-1-1
2-S~
~
(c,Aj~
Telephone Number
Telephone Number
~
Location of Facility
Municipality
Township
Quarter Section
Townshio
Range
-
Street Address
County
°~ook
Number
~
Property Identification
Number
Parcel Number
Nature of Operations Conducted at theAbove Location
C~J~eA-L~
~‘N~
FM~\)~L~’
Sec.
A
I—
z
C-)
-J
a.
a.
Sec. B
Water Pollution Control Construction
Permit No.
Date
Issued
NPOES PERMIT No.
Date
Issued
Expiration Date
Air Pollution
Control Construction Permit No.
Date Issued
Air Pollution Control Operating Permit No.
Date Issued
Sec.
C
~
0
U.a:
zo.
~
Describe Unit Process
ET.e~\2t~,
L-4)c~
~
L
U_b ~
~~3c*,Qx¼w~c,
Materials
Used
In Process
.
.
-
Sec.
0
~
a:j:
10-
a:
~
~
Describe Pollution Abatement Control Facility
—
e~Z~
—
.
RECEIVE
DEC31200
IL 532-0222
Tax
Certification for
Pollution
Control Fadilitlea
Page lof2
8/00
)
DAPC
~.
APC
151
(Rev.
8/00)
Sec.
E
(1)
Nature of Contaminants or Pollutants
Co
I—
z
z
2
z
p0
•
.C)
I—
~1
C.)
Ii.
-J
0
a:
I-
z
0
0
z
0
0
a.0
(5
z
I—
z
0
0
C.)
Tar Cert~Ication
for Pollution Control Facilities
Page 2
of2
8/00
Contaminant or Pollutant
DESCRIPTION
Material Retained, Captured or Recovered
DISPOSAL
OR
USE
(2)
Point(s)
of Waste Water Discharge
Plans and Specifications Attached
Yes
No
Are contaminants (or residues) collected
by the control facility?
Yes
No
(4)
Date
installation
completed
.~..statusof installation on
date of application
(5)
a.
FAIRCASHVALUEIFCONSIDEREDREALPROPERTY:
$
b.
NETSALVAGEVALUEIFCONSIDEREDREALPROPERTY:
$
c.
PRODUCTIVE GROSS ANNUAL INCOME
OF CONTROL
FACILITY:
$
d.
PRODUCTIVE NET ANNUAL INCOME
OF CONTROL FACILITY:
$
e,
PERCENTAGE CONTROL FACILITY BEARS TO WHOLE FACILITY VALUE:
Sec.
F
~folIowing
information is submitted in accordance with the Illinois Property Tax Code, as amended, and to the bestof my
knowledge, is true and correct.
The facilities claimed herein are ~polIution
control facilities” as defined in Section
11-10
of the
I
in
isPrope
a
C
e.
tA3ftQAa&14~
Signature
Title
Sec.
G
INSTRUCTIONS
FOR COMPILING
AND FILING APPLICATION
General:
Separate applications must be completed for each control facility claimed.
Do not mix types (water and air),
Where both air and
water operations are related, file
two applications.
If attachments
are needed,
record
them consecutively on an index sheet.
Sec. A
Sec. B
Sec.
C
Sec.
D
Information refers
to applicant as listed inthe tax records
and the person to
be contacted for
further details orfor inspection of
facilities.
Define facility location by street address or legal description.
A plat map location is required for facilities located
outside of municipal boundaries.
The property identification number is required.
Self.explanatory.
Submit copies of all permits issued
by local
pollution control
agencies.
(e.g. MSD Construction Permit)
Refers to manufacturing processes or materials on which pollution control fadllity-ls used.
Narrative description ofthe pollution
control facility, indicating that its primary purpose is to eliminate, prevent orreduce pollution.
State the type of control facility.
State permit number, date, and agencyissuing permit.
A
narrative description and a process
flow diagram describing the
pollution control facility.
Include a
listing of each major piece of equipment included in the claimed
fair cash value for real property.
Includean average analysis of the influent and effluent ofthe control facility stating-the
Co
collection efficiency.
Sec. E
List air contaminants, or water pollution substances released as effluents to the manufacturing
processes.
List also the final
disposal ofany contaminants removed from the manufacturing processes.
Item (1)— Refers to pollutants and contaminants removed from the process by the pollution control facility.
Item (2)— Refers to water pollution but can apply to water-.carried
wastes from air pollution control facilities.
Submit drawings,
which clearly show (a) Point(s) of discharge to receiving stream, and (b) Sewers and process piping to and from the control
facility.
.
Sec. F
Item (3)—If
the collected contaminants are disposed
ofotherthan as wastes, state the disposition of the materials,
and the value
in dollars
reclaimed by sale or reuse of the collected substances.
State the cost ofreclamation and related expense.
Item (4)— State the date which the pollution
control facility was firstplaced in serviceand-operated.
If not, explain.
Item (5)
—
This information is essential to the certification and assessment actions,
This
accounting data must be completed
to
activate project review prior to certification by this Agency.
Self-explanatory.
Signature must be a corporate authorized signature.
-
Submit
to:
-
Attention:
Attention:
Illinois EPA
Thomas MôSwiggin
Donald E.
Sutton
P.O.
Box 19276
Permit Section
Permit Section
Springfield.
IL
62794-9276
Division of Water Pollution Control
Division of Air Pollution Control
Equistar Chemicals, LP
2002
Application For
Certification (Property Tax
Treatment)
Pollution
Control
Facility: Air
Projects as of December, 2002
/_-
v~
~
Project Title/Description
Project#
Env. Cost
-
($M)
JD#/
Env
Proj.#
Details
-
.
Regulatory AnalysIs
.
Parallel Flare Vaporizer
~
MIO/001 01
$24
11923
-
Eliminated flaring 01168MM #
Ethylene peryear
No regulatory requirement
howeverthere was
a
reduction in air emissions
LDPE
Compressor Shutdown Improvements
MlO/00201
$180
25455
Reduced venting to atmosphere
No regulatory requirement
other than reduce air
emissions due to fewer
shutdowns
.
Lines 3&4
Hyper
Suction
GC Analyzer
~
MIO/01207
$43
Reduced ventingto atmosphere
No directrequirement
other than reduce air
emissions due to reduced
venting
Ethylene Unit Analyzer Vent
MlO/986232
.
$43
11896
Reduce VOC emissions
No direct requirement
other than
reduce air
emissions
Off-Gas Tie
Ins
MIO/986237
$4
11907
Reduce VOCemissions
No direct requirement
other than reduce air
emissions
EP Capacity Increase
.
MlO/986280
$49
Multiple
75MM#
Ethylene/year
towers
packing
compressors refrigeration
bottlenecks
Install Advance Maximum H2/C2 Analyzer
MlO/99101
$72
•
Reduce VOCemissions,
-
Improve process control and—
reliability
2.6MM t.bs
Ethylenelyear
No direct requirement
other than reduce air
emissions
Ethylene Unit Flare Metering
MIO/991 04
$20
11911/
99
.
Accurate emissions calculations
at flare
No
direct regulatory
requirement other than
accurate reporting of
emissions at flare.
Previouslybeing done via
mass
balance
EP Analyzer Replacement
MIO/99107
.
$133
11904
Reduce VOC emissions,
improve process control
and
reliability
No direct requirement
other than reduce air
emissions
Particulate Emission (PERP)
MlO/99203
$501
Reduce VOC and particulate
emissions
35 IAC 218
-
PP Flare Monitor
.
MlO/99214
$10
46393
Assure smokeless flare
operation reduced steam
consumption
(2.4 M lbs per hr.)
No
direct requirement
other than reduce air
emissions
and assured
compliance with 40 CFR
60.18
-
PP Flare Meter
MlO/99217
$167
46391
Accurate emissions
calculations
at flare
~
No direct requirement
other than
reduce air
emissions
LLDPE Flare Meter
MlO/99219
$286
24207
Accurate emissions
calculations
at flare
-
No direct requirement
other than
reduce air
-
-
emissions
V
D
o1z~
Project Title/Description
Line6 Suizer Compressor Upgrade
Tank Car Aromatics Loading
Project #
MlO/0021 2
MlO/01 107
Environmental
Cost ($M)
$34
$211
Completion
Date
Dec-02
Dec-01
Details
This project ensured
Line 6 could
meet current permit limits, production
and emissions by increasing the
capacity of the Suizer compressor.
The project reduce emissions
associated with the loading
and
unloading of rail
cars.
This project provided the LLDPE flare
header system with a measurement
system that will
satisfy the reporting
requirements
of theTitle V Permits.
Requlatorv Analysis
40
CFR 60 Subpart W and ODD
IAC 35218
No specific regulatory requirement,
but
ensures a system for reporting
accurate emission
in accordance with
theTitle V permit and
SARA
313.
Equistar Chemicals,
LP
2002 Application For Certification (Property Tax Treatment)
Pollution Control Facility: Air
-
-
Ethylene Unit AnalyzerVent
MlO/986232
$116
May-01
This project
installed analyzer exhaust
collection system to
eliminate direct
venting hydrocarbons to the
atmosphere.
35
IAC 218.428©
Particulate Emission Reduction Project
MlO/99203
$484
Sep-00
This project would allow gas to be
vented to the flare and notto
atmosphere.
-
35
IAC 218.411(b)
LLDPE Flare Meter
PP
Flare Meter
MlO/9921 9
MlO/99217
$318
$167
May-02
May-02
This project provide the PP flare
header system with a measurement
system that will satisfy the
reciuirements of theTitle V permit.
No specific regulatory requirement,
but
ensures a system for reporting
accurate emission in accordance with
the Title V permit and SARA
313.
PROOF OF SERVICE
I,
the
undersigned,
certify
that
I
have
served
the
attached
APPEARANCE
AND
RECOMMENDATION
upon the person to whom it
is directed, by placing them in
an envelope
addressed to:
-
TO:
Dorothy
Gm-in,
Clerk
Illinois Pollution Control Board
State of Illinois
Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
Steve Santarelli
Illinois Department of Revenue
101
West Jefferson
-
P.O. Box 19033
Springfield, Illinois 62794
W.S. Westlake
do Tax Dept.
Equistar
Chemicals, L.P.
One Houston Center
1221 -McKinney St.
Houston, Texas
77253-3
646
and mailing itby First Class Mail from Springfield, Illinois on October
15,
2003, with sufficient
postage affixed.
Robb H.
Layman
Special Assistant Attorney General
ARDC
#6205498
THIS FILING IS SUBMITTED
ONRECYCLED PAPER
