BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

NOTICE
APPEARANCE
RECOMMENDATION

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

MARATHON ASHLAND PETROLEUM, LLC

Platformer Vent Gas Scrubber

(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

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

MARATHON ASHLAND PETROLEUM, LLC

Platformer Vent Gas Scrubber

(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

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

MARATHON ASHLAND PETROLEUM, LLC

Platformer Vent Gas Scrubber

(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 or about 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 hereto.

[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

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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 Platformer Vent Gas

Scrubber that will reduce the hydrogen chloride content of the regeneration vent gas from

the continuous catalyst regeneration process in order to comply with applicable federal

MACT II regulations. The scrubber will reduce the hydrogen chloride content of the

process stream from a range of 500 and 1000 parts per million to less than 1 parts per

million. Hydrogen chloride is an acid gas and is regulated as a hazardous air pollutant.

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

Platformer Vent Gas Scrubber to prevent, eliminate or reduce air pollution, it is the

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

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

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

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 modification to the Platformer Vent Gas Scrubber satisfies the

aforementioned criteria, the Illinois EPA recommends that the Board

applicant’s requested tax certification.

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

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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

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Severence Tax Department

Marathon. Petroleum Company LLC

539 South Main Street

Findlay, OH 45840-3295

Telephone 4191422-2121

January 30,2006

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

Desulfunzation Unit (GDU)

Steam Supply to

#1 and #5 Flares

Crude Unit Off-Gas Handling

F-1 and 3F-2 CEMs

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

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

Platformer Vent Gas Scrubber

The amended applications are attached, please

fonvard to Mr. McKimey and begin the

review process.

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

Thank you for your help in this matter.

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APPLICATION FOR CERTIFICATION (PROPERTY TAX TREATMENT)

POLLUTION CONTROL FACILITY

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

Quarter Section

Platformer Vent Gas Scrubber

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2

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Air Pollution Control Construction Permit No.

Air Pollution Control Operating Permit No.

(Title V Permit)

Describe Unit Process

Materials Used in Process

Describe Pollution Abatement Control Facility

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Tm

Cerr$corion/or PoNzeion Conlrol Facililier

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The following information is submitted in accordance with the Illinois Property Tax Code, as amended, and to the best of my

knowledge, is true and correct. The facilities claimed herein are "pollution control facilities" as defined

in Section 11-10 of the

Illinois Property Tax Code.

Illinois Refining Division

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

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operations are related, file two applications. If attachments are needed, record them consecutively on an index sheet.

Information refers to applicant as listed in the tax records and the person to be contacted for furlher details or for 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 facility is used.

Narrative description of the pollution mntrol facility, indicating that its primary purpose is to eliminate, prevent or reduce pollution.

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

flow diagram describing the pollution control facility lnclude a listing of each major piece of equipment included in the claimed

fair cash value for real property. Include an

averaqe 

analysis of the influent and eftluent of the control facility stating the

collection efficiency.

List air mntaminants, or water pollution substances released as effluents to the

manufaduring processes. List also the final

disposal of any contaminants removed from the manufacturing processes.

-Refers to pollutants and contaminants removed from the process by the pollution control facility.

Item (2) -Refers to water pollution but can apply to watercarried wastes from air pollution control facilities. Submit drawings.

which clearly show (a)

Point(s) ofdischarge to receiving stream, and (b) Sewers and process piping to and from the control

(3) -If the collected mntaminants are disposed of other than as wastes, state the disposition of the materials, and the value

in dollars reclaimed by sale or reuse of the

colleckd substances. State the cost of reclamation and related expense.

-State the date which the pollution control facility was first placed in service and operated. If not, explain.

-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.

Donald E. Sutton

Division of Water Pollution Control

Division of Air Pollution Control

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Application for Certification (Property Tax) Pollution Control Facility

Marathon Petroleum Company LLC

Platformer Vent Gas Scrubber

Manufacturing. Process

Describe Unit Process:

Organic chloride is injected for the regeneration of the Platformer Unit catalyst. By-

products of regeneration are hydrochloric acid

(HCI) and chlorine gas (Clz). The vent gas

scrubber is designed to remove greater than 99.9% of the HCI and

C12 in the vent gas

Materials Used in Process:

Regenerator off-gas

Sodium hydroxide

Pollution Control Facilitv Description

Describe Pollution Abatement Control Facility:

I1 federal reeulations reauire the chloride content of regeneration vent

frob continuous catalyst yegeneration (CCR) be reduced to less than 10 ppm or a 97

reduction. To achieve this required reduction of HCl and C12 kom the vent gas

stream it was necessary to install a two-stage caustic scrubbing system.

The Platformer Unit CCR process produces small amounts of HCI and

which are contaminants that are regulated by the MACT

I1 federal regulations. To reduce

these contaminants to an acceptable level, a wet scrubber using caustic solution is

required to control emissions on the vent to the atmosphere. This is a two-stage process

with the first stage being an eductor that mixes dilute caustic with the CCR vent gas. The

combined stream of CCR vent gas and caustic solution then flows to the second stage, the

CCR Vent Gas Tower. The two-phase combined stream enters the tower below the

packed section and separates into a vent gas stream and a liquid caustic solution stream.

The vent gas passes upward through a shower of caustic solution and a packed bed

section that is washed with caustic solution liquid flowing downward through the

packing. The circulating caustic solution supply to the tower is fed into the tower at two

locations. The majority flows through a distributor located above the packed bed section,

and the remainder flows through a spray nozzle located below the packed bed. Spent

caustic solution is removed using a slip stream to the sewer. This two-stage vent gas

scrubber process has been successful in reducing the HCI and

Cl2 content kom between

1000 ppm to less than 1 ppm.

The new caustic scrubber system is designed to have a positive impact on the

environment as it removes inorganic hazardous air pollutants.

M:\DOCS\2006\Pollution Conml\Robinson

AFE

Arrachmml.doc

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ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE

P.O. BOX 19506, SPRINGFIELD, ILLINOIS

62794-9506 - ( 21 7) 782-21

Roo R. BLAGOIEVICH. GOVERNOR

Technical Recommendation for Tax Certification Approval

December 04,2006

Marathon Petroleum Company LLC TC-06-02-01B

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 125,204. 1 offer the following recommendation.

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

Platform Vent Gas Scrubber whose primary purpose is to control HCL

emissions on the vent to the atmosphere. HCL is an acid gas and is regulated as a

hazardous air pollutant. Because the primary purpose of this unit is to reduce or

eliminate air pollution, it is certified as a pollution control facility.

This 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

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

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

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

issue the requested tax Certification for this facility.

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