BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

NOTICE
RECOMMENDATION

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

MARATHON ASHLAND PETROLEUM, LLC

Gasoline Desulfurization Unit

(Tax Certification)

PROPERTY IDENTIFICATION NUMBER

51-34-1-21 or portion thereof

Electronic filing

Service by mail

Dorothy Gunn, Clerk

John S. Swearingen

Illinois Pollution Control Board

Marathon Ashland Petroleum

State of Illinois Center

Refinery Office Building

100 W. Randolph Street, Suite 11-500

Robinson, Illinois 62454

Chicago, Illinois 60601

Service by mail

Steve Santarelli

Illinois Department of Revenue

101 West Jefferson

Springfield, Illinois 62794

PLEASE TAKE NOTICE that I have today electronically filed with the Office of

the Pollution Control Board the

RECOMMENDATION

Illinois Environmental Protection Agency, a paper copy of which is herewith served upon

the applicant and a representative of the Illinois Department of Revenue.

Respectfully submitted by,

/s/ Robb H. Layman

Assistant Counsel

Date: January 4, 2007

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

Springfield, IL 62794-9276

Telephone: (217) 524-9137

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

MARATHON ASHLAND PETROLEUM, LLC

Gasoline Desulfurization Unit

(Tax Certification)

PROPERTY IDENTIFICATION NUMBER

51-34-1-21 or portion thereof

I hereby file my Appearance in this proceeding on behalf of the Illinois

Environmental Protection Agency.

Respectfully submitted by,

/s/ Robb H. Layman

Assistant Counsel

Date: January 4, 2007

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

Springfield, Illinois 62794-9276

Telephone: (217) 524-9137

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

MARATHON ASHLAND PETROLEUM, LLC

Gasoline Desulfurization Unit

(Tax Certification)

PROPERTY IDENTIFICATION NUMBER

51-34-1-21 or portion thereof

RECOMMENDATION

NOW COMES the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

(“Illinois EPA”), through its attorneys, and pursuant to 35 Ill. Adm. Code 125.204 of the

ILLINOIS POLUTION CONTROL BOARD’S (“Board”) procedural regulations, files

the Illinois EPA’s Recommendation in the above-referenced request for tax certification

of pollution control facilities. The Illinois EPA recommends a

of the request. In

support thereof, the Illinois EPA states as follows:

On December 29, 2005, the Illinois EPA received a request and supporting

information from MARATHON ASHLAND PETROLEUM, LLC, (“Marathon”)

concerning the proposed tax certification of certain air emission sources and/or

equipment located at its Robinson refinery in Crawford County, Illinois. On February 1,

2006, the Illinois EPA received an amended request for the same air emissions sources

and/or equipment. A copy of the relevant portions of the amended application is attached

[Exhibit A]

The property identification number or parcel number that is the subject of a tax certification request is

typically identified in the Illinois EPA’s Recommendations and Board orders as part of the case caption,

presumably because of the ease with which applicants and local tax assessors alike can identify the affected

property. The property identification or parcel numbers for these cases are usually derived from the

application forms (i.e., APC 151) that are filled out by the applicant and submitted to the Illinois EPA. In

this instance, it should be noted that the parcel number identified in the application form submitted by

Marathon Ashland contains a typographical error. The numbers depicted on the application form, shown in

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

The applicant’s address is as follows:

Marathon Ashland Petroleum, LLC

Refinery Office Building

Robinson, Illinois 62454

The subject matter of this request consists of a Gasoline Desulfurization

Unit, which, through a two-step process utilizing a Selective Hydrogenation Unit and a

Hydrodesulfurization Unit, allows the refinery to reduce the sulfur content of its gasoline

in order to comply with federal gasoline content requirements. The federal requirements

are meant to remove sulfur in the gasoline pool and thereby reduce sulfur dioxide

emissions caused by the use of gasoline by automobiles and other gas-powered engines.

Section 11-10 of the Property Tax Code, 35 ILCS 200/11-10 (2002),

defines “pollution control facilities” as:

“any system, method, construction, device or appliance appurtenant

thereto, or any portion of any building or equipment, that is designed,

constructed, installed or operated for the primary purpose of: (a)

eliminating, preventing, or reducing air or water pollution… or (b)

treating, pretreating, modifying or disposing of any potential solid, liquid,

gaseous pollutant which if released without treatment, pretreatment,

modification or disposal might be harmful, detrimental or offensive to

human, plant or animal life, or to property.”

Pollution control facilities are entitled to preferential tax treatment, as

provided by 35 ILCS 200/11-5 (2002).

Based on information in the application and the underlying purpose of the

Gasoline Desulfurization Unit to prevent, eliminate or reduce air pollution, it is the

Illinois EPA’s engineering judgment that the described project and/or equipment may be

Exhibit A attached hereto, identify the first two digits of the property’s parcel number as 54. Prior tax

certification requests for the refinery, as received by the Illinois EPA and eventually acted upon by the

Board, have employed a parcel number whose first two digits are 51. Prior to this filing, the undersigned

attorney contacted Marathon Ashland’s designated representative, Mr. Dennis Baker, regarding the

apparent discrepancy. Mr. Baker confirmed that the correct parcel number for this tax certification request

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

considered as “pollution control facilities” in accordance with the statutory definition and

consistent with the Board’s regulations at 35 Ill. Adm. Code 125.200.

[Exhibit B].

Because the Gasoline Desulfurization Unit satisfies the aforementioned

criteria, the Illinois EPA recommends that the Board

the applicant’s requested tax

Respectfully submitted by,

/s/ Robb H. Layman

Assistant Counsel

DATED: January 4, 2007

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

Springfield, Illinois 62794-9276

Telephone: (217) 524-9137

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

CERTIFICATE OF SERVICE

I hereby certify that on the 4

day of January, 2007, I electronically filed the

following instruments entitled

NOTICE, APPEARANCE

RECOMMENDATION

Dorothy Gunn, Clerk

Illinois Pollution Control Board

100 West Randolph Street

Chicago, Illinois 60601

and, further, that I did send a true and correct paper copy of the same foregoing

instruments, by First Class Mail with postage thereon fully paid and deposited into the

possession of the United States Postal Service, to:

Steve Santarelli

John S. Swearingen

Illinois Department of Revenue

Marathon Ashland Petroleum

101 West Jefferson

Refinery Office Building

Robinson, Illinois 62454

Springfield, Illinois 62794

/s/ Robb H. Layman

Assistant Counsel

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

Severence Tax Department

Marathon Petroleum Company LLC

539 South Main Street

Findlay, OH 45840-3295

Telephone 4191422-2121

January 30,2006

Bureau of Air -Number

1021 North Grand Avenue -East

Re: Application for Certification Pollution Control Facility

Dear Mr. Sutton:

Prior to December 31,2005, Marathon Petroleum Company submitted five applications

for facilities at our Robinson Refinery in

Crawford County, Illinois. The applications

were for the following units:

Platformer Vent Gas Scrubber

Desulfiuization Unit (GDU)

Steam Supply to

Crude Unit Off-Gas Handling

F-1 and 3F-2 CEMs

Shortly after the start of the new year, I contacted Mr. Floyd McKinney and advised him

that Marathon would be submitting amended applications for two of the units, the

Platformer Vent Gas Scrubber and the GDU.

The amended applications are attached, please forward to

Mr. McKinney and begin the

review process.

If there are questions or comments, please contact me at 419-421-3759.

fo; your help in this matter

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

APPLICATION FOR CERTIFICATION (PROPERN TAX TREATMENT)

POLLUTION CONTROL FACILITY

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

539 South Main Street 

Gasoline Desulfurization Unit 

(GDU) 

ee Attached 

ee Attached 

IL 532-0222

(Rev. 8/00)

Tar

Cerri/imlion/or Pollerion Cor~lrol Faciliries

8/00 

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

Set. E I (1) Nature of Contaminants or Pollutants

2

(2) Point(s) of Waste Water Discharge

Waste Water Treatment

Plans and Specifications Attached 1 Yesn

Are contaminants (or residues) collected by the control facility?

Date installation completed March

status of installation on date of application

a. FAIR CASH VALUE IF CONSIDERED REAL PROPERTY:

$106,404,865.27

b. NET SALVAGE VALUE IF CONSIDERED REAL PROPERN:

Material Retained, Captured or Recovered

Contaminant or Pollutant

DISPOSAL OR USE

bulfur in gasolind The sulfur is collected

c. PRODUCTIVE GROSS ANNUAL INCOME OF CONTROL FACILITY:

I d. PRODUCTIVE NET ANNUAL INCOME OF CONTROL FACILITY:

and routed to the amine

units for treatment.

I e. PERCENTAGE CONTROL FACILITY BEARS TO WHOLE FACILITY VALUE:

INSTRUCTIONS FOR COMPILING AND FILING APPLICATION

Z

2

I

Genera Separale appl car ons m~sl

oe wmp eted lor each wntro lac lily c a med

x types (water and all) Where both atr and

water operattons are

related. fie Wo app cal ons I anachments are neeoeo, record hem wnsewttvely on an noex sneel

Tne fo low ng inforrnauon IS sum tled n accoraance w tn tne linois Propeny Tax Coae, as amended ano to tne Dest of my

knowleaqe. 1s true and correct

lac11 I es caimea nere n are po lut on contro lac .lies" as defnea in Secllon 11-10 of the

Illinois ~ropedy Tax Code.

Illinois Refining Division

I outside of municipal boundaries, the propetty identification nuniber is reljuired. '

I Self-explanatory. Submit wpies of all permits issued by local pollution wntrol agencies. (e.g. MSD Construction Permit)

Information refers to applicant as listed in the tax remrds and the person to be mntacled for furiher details or for inspection of

facililies. Define faalilv location bv street address or leaal descriotion. A olat mao lowlion is reauired for facilities located

Refers to manufacturing processes or materials on which pollution wntrol facility is used.

Narrative description of Me

pollution wntml facility, indicating that ib primary purpose is to eliminate, prevent or reduce pollution.

State the type of mntrol facility. Stale permit number, date, and agency issuing permit. A narrative description and a process

Row diagram describing the

pollution mntrol facilik. Include a listing of each major piece of equipment included in the claimed

fair wsh value for real pmpelty, Include an

averaqe 

analysis of the influenl and efRuent of the mntrol facility stating Me

contaminants. or water wllution substances released as ef uents to the manufacturino orocesses. List also Vle final

o sposa of any mnlarn nants removed horn he man~lact~r

lulants and mntam nants remored from tne process

by

he poll~t on control laul ty

y to walercarned

-If the mllected wnlaminants are disposed of other than as wastes, state the disposition of the materials, and the value

~n dollars reclaimed bv sale or reuse of the wlleckd substances. State Me wst of reclamation and related exoense.

ltem (4) - State the date wn ch lne po Luon wntro faulaty was first p.am in service and operate0 If not. exp ain

- Thls .nformallon is essenllal lo Me cehtwtion and assessment acLons Thls acmunl ng aata mJst oe Wmp eted to

Self-explanatory.

an

Al

Donald E. Sutton

Division of Water Pollution Contml

Division of Air Pollution Control

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

Application for Certification (Property Tax) Pollution Control Facility

Marathon Petroleum Company

Gasoline Desulfurization Unit (GDU)

Manufacturing Process

Describe Unit Process:

is to install a Gasoline Desulfiuization Unit (GDU) at the Robinson refinery

to remove sulfur from petroleum fuels to meet government regulations for mandated

sulfur levels in gasoline. Sulfur atoms can be attached or imbedded anywhere in the

various hydrocarbon molecules and mechanical processes such

as distillation can not

remove this sulfur. Therefore, the following two-step GDU process is required for sulfur

Selective Hydrogenation Unit (SHU)

Hydrodesulfurization Unit

The feed streams for the GDU are from the Fluid Catalytic Cracking Unit (FCCU) and

Light Coker Naphtha which contain almost all of the sulfur in the gasoline pool. With

the use of reactors and splitters, the SHU and HDS remove sulfur from the raw material

as it comes out of the FCCU and the Coker units. In this process, the naphtha

is separated into two streams: light naphtha (low-sulfur product) and heavy naphtha

(high sulfur). The goal is to reduce the sulfur content to an acceptable reading of 50 ppm

or less. The desired results are

achleved with the Prime-@ Process developed by Axens.

Materials Used in Process:

Axens (HR806, ACT 068, HR 841, ACT 072, and ACT 845s)

Betz Max-Amine (57c, 70b)

Ondeo-Nalco Ecl014a

Lean MDEA and Rich MDEA

Hydrogen rich gas

Naphtha Splitter

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

Section D -Pollution Control Facility Descri~tion

Describe Pollution Abatement Control Facility:

Government mandated environmental regulations have identified sulfur in petroleum

fuels as an air pollutant. It has also been state that the presence of sulfur in gasoline

retards pollution control equipment on motor vehicles, thus increasing tailpipe emissions

that adversely affects human health and the environment. Therefore, to eliminate the

source of this contamination under "Tier 2" of the Clean Air Act, sulfur in the gasoline

pool must be reduced to 30 ppm by January 1,2006. The sole purpose of the Robinson

Gasoline Desulfurization Unit (GDU) is to reduce the sulfur content in the FCCU and

Light Coker Naphtha (LCN) streams with no economic benefits resulting to the refinery.

The GDU was designed, constructed, installed and operated for the primary purpose of

reducing the sulfur content of hydro-carbon fuels. Without such treatment of the

and Light Coker Naphthas' streams, sulfur would continue to be present in the petroleum

fuels which would result in air pollution in excess of the "Tier

2" standards. Should

sulfur not be removed from petroleum fuels, it will interfere with the vehicle catalytic

converter's ability to remove

and other "critical pollutants" resulting in the creation

of smog which causes lung inflammation, reduced lung function, breathing discomfort as

well as damaging crops and forests.

In summary, the GDU was constructed only to meet a governmental mandate which

enables the Robinson

refinew to stay in business. The Robison refinerv receives no

economic incentives or financial benefit from the GDU. The GDU wili reduce the sulfur

content in naphtha from a maximum of 1,769 ppm down to an acceptable nominal sulfur

content of 50 ppm, thus reducing smog and enhancing human health.

Below is an overview of the process:

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

GDU Overview

Preheat Section

1. Feed drum provides surge capacity, hold up capacity

2. Hydrogen injection point to SHU feed

Provides temp. control for the SHU reactors

SHU Reactors

1. Decrease diolefins present in the feed sources

2. Conversion of light sulfur compounds to heavy sulfur compounds

Minor octane increase due to isomerization of external olefins to internal olefins

(lugher octane number)

Naphtha Splitter

1. Fractionate SHU

Rx

effluent into light naphtha and heavy naphtha stream

Purpose of First HDS Reactor

Decrease sulfur in the splitter bottoms stream down to sulfur specifications

Rx

1. Complete the residual desulfurization reactions (10-15%)

2. Prevent recombination of H2S and Mercaptans to form sulfur compounds

74C-9 Amine Absorber

Uses Lean Amine to remove H2S from the recycle hydrogen stream

Recycle Compressor

1. Takes suction from the KO drum and "recycles" the hydrogen for reuse in HDS

2. Recycle hydrogen is used for:

in the First HDS

Rx

b. Treat gas to the HDS feed stream

Process flow diagrams of the

SHU and HDS are attached.

M:\DOCS\2006Wollution Control\Robinson AFE 229 

Auachment.doc

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

HDS Section Process Flow Diagram

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *

ENVIRONMENTAL PROTECTION AGENCY

GRAND AVENUE EAST. P.O. BOX 19506, SPRINCFIELI), ILLINOIS 62794-9506 - ( 21 7) 782-21 13

Rou R. BLAGOIEVICH, GOVERNOR

P. SCOTT, DIRECTOR

Technical Recommendation for Tax Certification Approval

December 04,2006

Subject: Marathon Petroleum Company LLC TC-06-02-01A

This Agency received a request on February 01, 2006 from Marathon Petroleum Company LLC for an

Illinois EPA recommendation regarding tax certification of air pollution control facilities pursuant to 35

Adm. Code 1251204. 1 offer the following recommendation.

The air pollution control facilities in this request include the following:

Gasoline Desulfurization

Unit(GDU) whose primary purpose is to remove Sulfur

from petroleum fuels to meet government regulations for mandated Sulfur levels. The

reduced Sulfur levels in turn reduces the amount of

SO2 emissions. Because the primary

purpose of this unit is to reduce or eliminate air pollution, it is certified as a pollution

control facility.

is located at Route 33, Robinson, Crawford County

The property identification number is Part of 54-34-1-21

Based-on the information included in this submittal, it is my engineering Judgement that

the proposed facility may be considered "Pollution Control Facilities" under 35 IAC

125.200(a), with the primary purpose of eliminating, preventing, or reducing air pollution,

as.otherwise provided in this section, and therefore eligible for tax certification from

the Illinois Pollution Control Board. Therefore, it is my recommendation that the Board

issue the requested tax Certification for this facility.

PRINTED ON RECYCLED PAPER

ELECTRONIC FILING, RECEVIED, CLERK'S OFFICE, JANUARY 4, 2007

* * * * * PCB 2007-056 * * * * *