NOTICE
APPEARANCE
CERTIFICATE OF SERVICE

•

CE~VE~D

CLERK’S OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL

BOARJi~JN

022004

OF THE STATE OF ILLINOIS

STATE

OF QtINOIS

Pollution Control Board

CONOCOPHILLIPS

COMPANY

)

Low Sulfur Gasoline Project

—

Wood River Refinery

)

•

)

•

)

PCBO4-

)-1

•

)

(Tax Certification)

PROPERTY IDENTIFICATION NUMBER

)

19-1-08-35-00-000-001

)

NOTICE

TO:

Dorothy Gunn, Clerk

Michael Kemp

Illinois Pollution

Control Board

ConocoPhillips Company

State of Illinois Center

404 Phillips Building

100 W. Randolph Street, Suite 11-500

Bartlesville,

Okalahoma

74004

Chicago, Illinois 60601

Steve Santarelli

Illinois Department of Revenue

101

West Jefferson

P.O. Box 19033

Springfield, Illinois 62794

PLEASE

TAKE NOTICE that I have today filed with the Office of the Pollution Control

Board the APPEARANCE and RECOMMENDATION ofthe Illinois

Environmental Protection

Agency, a copy ofwhich is herewith served upon the applicant, ConocoPhillips Company, and a

representative ofthe Illinois Department ofRevenue.

Respectfully submitted by,

Robb H. Layman

Special Assistant Attorney General

Date:

June 1, 2004

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

RECE~VE~

CLERK’S OFFICE

JUN

022004

BEFORE THE ILLINOIS POLLUTION CONTROL BO~4~-E

OF ILLINOIS

OF THE STATE OF ILLINOIS

Pollution Control Board

CONOCOPHILL1IPS COMPANY

)

Low Sulfur Gasoline Project

—

Wood River Refinery

)

•

)

PCB04~~1~

•

)

(Tax Certification)

PROPERTY IDENTIFICATION NUMBER

)

19-1-08-35-00-000-001

)

APPEARANCE

I hereby file my Appearance

in this

proceeding

behalf of the

Illinois

Environmental

Protection Agency.

Respectfully submitted by,

•

Robb H. Layman

•

Special Assistant Attorney General

Date:

June

1, 2004

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

CLERK’S OFFICE

•

JUN

022004

BEFORE THE ILLINOIS POLLUTION CONTROL BOAR~~t~

OF THE STATE OF ILLINOIS

arcS

CONOCOPHILLIPS

COMPANY

)

Low Sulfur Gasoline Project

—

Wood River Refinery

)

•

)

PCB04-~4

•

)

(Tax Certification)

PROPERTY IDENTIFICATION NUMBER

)

19-1-08-35-00-000-001

)

RECOMMENDATION

NOW COMES the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY (“Illinois

EPA”), through its

attorneys, and pursuant to 35

Ill. Adm. Code

125.204 ofthe ILLiNOIS

POLUTION CONTROL BOARD’S (“Board”) procedural regulations, files the Illinois EPA’s

Recommendation in the above-referenced request for tax certification ofpollution control

facilities.

In support thereof, the Illinois EPA states as follows:

On December 31, 2003,

the Illinois EPA received a request and supporting

information from CONOCOPHILLIPS COMPANY (“ConocoPhillips”) concerning the proposed

tax certification ofcertain air emission sources andlor equipment located at its

Wood River

Refinery in Madison County, Illinois.

A copy ofthe relevant portions ofthe application is

attached hereto.

Exhibit

Al.

•

The applicant’s address is as follows:

•

ConocoPhillip.s Company

900 South Central Avenue,

P.O. Box 76

Roxana, Illinois

62084

The pollution control facilities involved in this request are located at the

aforementioned address and consist ofthe installation ofnew and/ormodified equipment,

described as the Low Sulfur Gasolineproject,

that will allow the Wood River Refinery to

produce lower-sulfur

gasoline, thus reducing sulfur dioxide emissions.

The emission reductions

are required by the United States

Environmental Protection Agency’s Tier 2 regulations.

The

initial phase ofthe project Will allow the Wood River Refinery to

produce lower sulfur gasoline

by 2004 and will be accomplished by the desulfurization of light catalytic naphtha, heavy

catalytic naphtha and light straight run gasoline.

The Illinois EPA issued the Wood River Refinery a joint construction

and

operating permit for the first phase ofthe Tier2 project on June 13, 2002.

Exhibit

BJ.

Additional details concerning the nature ofthe project are included therein.

Section 11-10 ofthe 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 waterpollution... or (b) treating, pretreating, modifying

or disposing ofany

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

IILCS 200/11-5 (2002).

Based on information in the application and the underlying purpose ofthe Lo~

Sulfur Gasoline project to prevent, eliminate or reduce air pollution, it is the 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.

Because the Low Sulfur Gasoline project and/or equipment satisfy the

aforementioned criteria, the Illinois EPA recommends that the Board issue the applicant’s

requested tax certification.

•

Respectfully submitted by,

•

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

Robb H. Layman

Special Assistant Attorney General

DATED:

June 1,

2004

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

SUBMITFED

ON RECYCLED PAPER

CERTIFICATE OF SERVICE

I hereby certify that on the

1st

day ofJune, 2004, I did send, by First Class Mail, with

postage thereon fully paid and

deposited into the possession ofthe United States Postal Service,

one (1) original and nine (9) copies ofthe following instruments

entitled

NOTICE,

APPEARANCE and RECOMMENDATION to:

Dorothy Gunn, Clerk

Illinois

Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, Illinois

60601

and a true and correct copy ofthe same foregoing instruments, by First Class Mail with postage

thereon fully paid and deposited into the possession ofthe United States Postal Service, to:

Steve Santarelli

Michael Kemp

Illinois Department ofRevenue

ConocoPhillips Company

101 West Jefferson

404 Phillips Building

P.O. Box 19033

Bartlesville, Okalahoma

74004

Springfield, Illinois

62794

By: Robb H. Laym

Special Assistant Attorney General

This filing

is submitted on recycledpaper.

•

f/~O’?o

—‘~‘--~Z-:~)

•

MichaelKemp

ConocoPhillips

SLOG Plaza Office

Building

Bartlesville

74004

Phone:

918

661-9055

Fax:

(918)

662-2212

Michael.D.Kemp~conocophillips.

corn

December 30, 2003

Mr. Don Sutton

Division of Air Pollution Control

Illinois EPA

1021

North Grand Avenue East

Springfield, IL

62701

RE:

Application for Certffication

Low Sulfur Gasoline Project

Dear Mr. Sutton;

Attached is a completed Application

for Certification (Property Tax Treatment) for the

low sulfur gasoline project at the Wood River Refinery in

Madison County IL.

As advised

in the application,

Mr. Neal Sahni, (phone number 618-255-2478) can

answer technical questions related to the application.

Any questions regarding values

or financial information should be addressed to me.

look forward to talking with you.

Sincerely,

Michael Kemp

~ECEVVED

DEC 31

2003

—

he~ri-

IL ~32.O222

A’~C SI

(Rev.

8/00)

Tax

C~rtflcano~fi,r

Po!!uij~’~

control Fa-Jitü~

Par!

of.’

8J’~o

T~.sAgency

authorized

request

this

~n~brmat~On

under Illino,,

Rcviscd

St~tucs,

1979,

Chapter.

120, Section 502~-~.

I~urc

this

informatcn

voluntarj.

H~w~v~r,

tai~re

~crnp~y

ccu1~

prcvcnt

your

~pp1ieatiar.

from

be~ngpr~~ces~cd

could

res.~tt

denlni

orycur

ap~lic~tion

fcr ceriiflcaticr..

APPLICATION FOR CERTIFICATION

(PROPERTY

TAX

T~.EATMENT)

POLLUT1OP~’CONTROLFACILITY

•

WATER

0

ILUNOIS ENVIRONMENTAL

PROTECTION AGENCY

P. 0.

~ox

19276,

5prin~fle1d.

62794-9~76

FO~AGENCYUSE

F~8NO

Date

Received

Certticaticn

No.

Date

Sec. A

Company Name

ConocoPhillips_Company

Person

Authorized

to

Receive Certification

Person

to Contact

(or

Addition3l Details

•

 Michael

 Kemp

 Neal Sahni

Street Address

•

Street

Address

404 Phillips Building

 900 S.

 Central

 Ave.,

P.

 0. Box

76

Municipality,

State

& Zip

Code

Municipality,

State

& Zip Code

 Bartlesvilleg

OK

74004

 Roxana,

IL

62084

 Telephone Number

 Te~phorie

Number

 918-661—9055

..•

 618-255-2478

Location of Facility

Munic~paIity

 Township

Quarter Section

Township

Range

Street Address

SoQk Number

900 S.

 Central Ave.

 Madison

Property

Identification

Number

 Parcel

Number

19—1-08-35-00-000-001

Sec. B

 Nature ofOperatons

Conducted

at the

Above Location

 Petroleum Refining

~

~°

—

Water PollutionControl

Construction

Permit No.

N/A

Date

saued

NFOES

PERMIT No,

N/A

Date

Issued

Expiraton

Date

Air Pollution Control

Construction

PermitN~.

01120044

Date ~ssued

June 13, 2002

Air

Polution Control Operathig

permit

No.

01120044

—

Date

Issued

June

13,2002.

Sec.

C

 Describe Unit

Process

-—

Hydrotreating intermediate petroleum products.

.~,

‘hL

“

Mat~iiis

Used in Proces.s

Crude

oil

and/or

its

petroleum

derivatives,

water,

cat

hydrogen

and

chemical

additives.

•

DEC

?003

Sec.

0’

Describe Poilutlon Abatement

Control

Facility

USEPA’s Tier II

regulations

require

refineries

limit

the sulfur contentofgas~~~

parts per

million

weight (ppmw) on an annual

basis.

The

\Vood River Refinery

plans

to meet the

required

Tier

gasoline

specifications

through a

combination ofinstallation of

new

equipment and

the

revamping of

existing

equipment.

The LSG project is

divided

into

two phases.

Phase

of the

project

focuses

the desulfurization of.the

Light

Catab-tic

Naphtha

(LCN). Heavy Catal

tic

Naphtha (HCN). and Light Straight Run (LSR)

Gasoline.

•

SEP-17—2003

 10:01

 PPCO

F’TREC

9186622212

P.

02/02

Tax (~erscJka~loe

for

F~ilulkui

Control

Fa~ilill~$

Pa~e2ofZ

Sec.

(1) Nature

of Conteminants

or Pollutants

—•

•

Material Retairi~d,

Captured

ReCgVered

Coritamiriantor Pollutant

DESCRIPTION

DISPOSAL OR USE

Siil fur

(low

ciil

far

p~o1

irte)

•

Sul fur

Dioxid~e-

Sold

elomen-tarsul fur

~2)

Point(s) of Waste Water

Discharge

•

—~

S•

Plans and Specffications Attached

Yes

Arecontdminants

(or residues) collected by the

control facility?

Yes

(4)

Date installation completed

9130/2003

status of

instaflation on date of application

Op~rati

(5)

FAIR

CASH

VALUE

CONSIDERED REAL

PROPERTY:

‘(

~ ~S

Oo()

—

NET

SALVAGE

 vALUE

IFCONSIDERED REAL PROPERTY:

3 5~3~

~9a5Q

•

PRODUCTIVE

GROSS ANNUAL INCOME

CONTROL FACILITY;

‘~:5~I3~

—

PRODUCTIVE

NET ANNUAL INCOME OF CONTROL FACILITY;

~ERCENTAGE

CONTROL

FACILITY 8EARSTO WHOLE FACILITY

VALUE:

°,~

‘hi~

cci/,,

$e~.

F

The

following information is submitted in

ace

rdsnce with the Ill Is P1

party Tax

Code,

as amended, ~nd

the

best of my

knowledge, Is true and correct.

The facilihs claimed

herein are

~poUution

control facllit1es~

as defined

Section

11-10

of the

Sec.

IllinoIs

Property Tax

Code.

~21~1L~L

QoL~

1~rO~

e~J~Cç

S~gnature

Tale

~ciiryi..~.

esi~h.

——

IN$TRUCTIONS FOR COMPIUNG AND FlUNG APP~ATI0N

General:

Separate

applications must

be completed

for

each control

facility claimed.

not mix types

(water and

air).

Where both air and

water operations are

related,

file two applIcatJc~.s.

Ifaftct’xs~nts

are

needed,

record

them

consecutively

on en

Index shoot.

Sec.A

Information refers

applicant

listed

the

tax

records

and

the person to

becontacted for further deiaiis

or for

inspection

facilities.

Ddne facility location

~freet

address

legal

descripilon.

 p1st

map

location is

required

for faciuites located

outside of municipal boundaries.

The

property

IdentIfication

 numb& is

required.

Sec.

Self-explanatory.

Submit copies

of all permits issued

local pollution

control

agencies.

 (e.g.

MSD

Construction Permit)

Sec. C

Refers to manu

c~uitrsg

processes or

materials

on which

 pollution

control facility IS used.

Sec. I)

 Narrative description

the pollution control

faelity,

indIcating

that

Its primary purpose

is to

eliminate, prevent or reduce

pollution.

State the type

ofcontrol

fàdllty.

 State

permit

nuniber~

date,

and

ageney

issuing permit. A narrative

d~$CIiPtiOnand

a process

flow

diagram

describing the

pQlIvt104 cc

cIj~~.

Include

a listing of

each

major

piece of equlprl

ntincluded in

the cialmeti

fair

cash value

for

r~sl

property.

Include an

 evera~eanalysis

of the influent

and

effluent of the control f~clIlty

statinO the

collection efficiency,

•

Sec.

List

air

contaminants,

or water pollution

substances released

effluents

to the

marnifactr.nirig processes.

List also the

final

disposal

of any

contarninante

removed from

the nianufacturing processes.

Item

(1)— Refers to pollutants and contaminants removed from

the process

by the

pollution control faclity.

lten

(2)

—

Refers to water poUution

but

can

apply towater-carried wastes from air pollution

control

facilities.

Submit drawings

which deariy show

(a)

Point(s)

Of discharge to

receiving stream,

and

Ib) Sewers and orocess

piping•

O~I1dftOffl

the co~trol

facility.

Item (3)

—

If the

 collected contaminants

are

disposed of

other

than as

wastes,

state the

dispoSition

of the materials,

and

the value

in dollars

reclaimed by

aale

reuse

ofthe

collected su

stances.

State the

cx,st

of reciamation and related expense,

Item (4).. State the

date

which the

pollution

control

fac~ity

was first placed

Irs

~~rvlcs

and operated.

rot,

explaIn.

Item (5~

—

This

nformation

essential

ic the cerlificatlon and

assessment

actIons.

This

accounting data

must be completed to

activate

project

review

prior to

cerWlcaton

thIs

Agency.

L590•

Self~xplanatory.Signature must be

a corporate

authorized signature.

•

Submit to:

Attention:

•

Iltinols EPA

‘

 Thomas

McSwiggln

Donald

Sutton

P.O.

Box

19276

Permit Section

 Permit Section

•

Springfield. IL

G2794-9276

Division

Water

Pollution Ccntrol

DivIsion

Air Pollution

Control

TOT~iLP.02

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

P.O.

Box

1 9506,

SPRINGFIELD,

ILLINOIS

62794-9506

RENEE CIPRIANO,

DIRECTOR

217/782-2113

JOINT CONSTRUCTIQN AND OPERATING PERMIT

 NSPS SOURCE

NESHAP

SOURCE

PERMITTEE

Wood River Refinery

Attn:

 Gina

P.

 Nicholson

P.O.

 Box 76

Roxana,

 Illinois

62084

Application No.:

01120044

 I.D. No.: ll9~

Applicant’s Designation: WRR-69

 Date Received:

 December 28,

2001

Subject: Tier

2

 Project

Date Issued: June 13,

2002

 Operating Permit Expiration

S

 Date:

 June

13,

2007

Location:

 900 South Central Avenue,

 Roxana

This Permit

 is hereby granted to the above-designated Permittee to CONSTRUCT

and OPERATE emission source(s)

 and/or air pollution control e~uipment

consisting of

 a the first phase

of

 a Tier

 2 project,

 that

 is, ~rariouschanges

to the refinery to produce lower sulfur gasoline,

 as described

 in the above-

referenced application.

 This Permit

 is subject to standard conditions

attached hereto and the following special condition(s)

1.0

 Unit Specific Conditions

1.1

 Unit:

 Tier

 2 Project

1.1.1

 Description

This

 construction permit

 is the first phase

 of a single

S

project that will allow the refinery to produce lower

sulfur gasoline by 2004,

 as required by the USEPA Tier 2

gasoline sulfur requirements.

 Phase

 1 will accomplish

desulfurization

 of light catalytic naphtha

 (LCN), heavy

catalytic naphtha

 (HCN),

 and light straight

run

 (LSR)

gasoline.

S

S

The catalytic naphtha splitter will fractionate

 feed into

light,

 intermediate,

 and heavy catalytic naphthas.

Reboilers required in this process will demand additional

steam from the existing boiler

17.

HCN will feed the new heavy catalytic naphtha hydrotreater

(HCNHT),

 which uses 1-iydrodesulfurization to reduce the

sulfur content of gasoline.

 Existing heater F-l will be

modified to effectively heat the feed to the reactor.

The light oil treater-east train

 (ELOT)

 will be modified

to reduce the sulfur content of the

LCN

 from the

CNS

and

other streams through the use of caustic technology.

Installation of a new LOT flare will remove hydrocarbon

rich vent gas from this process.

~Exh~.f 8

GEORGE

RYAN,

GOVEF

Page

2

The

gasoline

hydrotreater

(GHT)

will

modified

that

it can hydrotreat LSR gasoline.

As

 a result,

 the existing

alky HM-l heater will have to fire

at

 a higher rate.

There will be additional sulfur loading to the Sulfur

Plant from the Tier

2

 (Phases

 1 and 2),

 however,

the

Sulfur Plant will continue to operate within its design

capacity.

These modifications will not result in an increase

in.

crude throughput.

1.1.2

 List

 of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Emission

Control

Equipment

CNS

 Catalytic Naphtha

 Splitter

 None

HCNHT

 Heavy Catalytic Naphtha

Hydrotreater

‘

 None

ELOT

S

Modification to the Light

 OiJ.

Treater

 East Train for

Caustic Extraction Section

and Addition of New Caustic

Regeneration Section

LOT Flare

GHT

 Gasoline Hydrotreater

 None

Fugitives

 Fugitive Emissions

 from New

Components Associated with

the Tier

 2 Project

None

S

1.1.3

 Applicability Provisions and Applicable Regulations

a.

An

 “affected fuel gas combustion device”

 for the

purpose of these unit-specific conditions,

 is the

F-l

Charge Heater and the new LOT Flare

 as described in

Conditions 1.1.1 and 1.1.2.

S

i.

A.

 This permit is issued based upon the

affected fuel gas combustion devices ~

being subject to the NSPS for Petroleur~

Refineries,

 40 CFR 60 Subparts A and

3.

The Illinois EPA administers the NSPS for

subject sources

 in Illinois pursuant to a

delegation agreement with the USEP’A.

B.

 The Permitte’e shall not burn in the

affected fuel gas combustion device any

fuel gas that contains hydrogen sulfide

(H2S)

in

excess

 of 230 mg/dscm

 (0.10

gr/dscf).

 The combustion in a flare of

process upset gases or fuel gas that is

released to the flare as

 a result

 of’

relief valve leakage or other emergency

Page

3

malfunctions

 is exempt from this

 paragraph

40

 CFR 60.104 (a) (1)

ii.

A.

 The Permittee shall notcause or allow the

emission of

 smoke or other particulate

 matter, with an opacity greater than 30

percent,

 into the atmosphere from the F-l

Charge Heater except as provided below

35

IAC 212.123(a).

5

S

B.

 The emission

 of smoke or other

particulate matter from the F-l Charge

Heater may have an opacity greater than

30 percent but not greater than 60

percent for a period or periods

S

aggregating

minutes

any

minute

period

provided

that

such

opaque

emissions permitted during any 60 minute

period shall occur from only one such

emission unit located within a 305 m

(1,000

ft)

 radius from the center point

of any other such emission unit owned or

operated by such person,

 and provided

further that such opaque emissions

permitted

from

each

such

emission

unit

shall be limited to

 3 times in any 24

hour period

35

 IAC 212.123(b)).

iii.

 The Permittee shall not cause or allow the

emission of carbon monoxide

 (CO)

 into the

atmosphere from the F-l Charge Heater to

exceed

200

ppm,

corrected

percent

excess

air

35

 IAC 216.121

This

permit

issued

based

 up~nthe equipment leaks

associated with

CNS

 Unit, HCNHTUnit,

 and ELOT being

subject

the

Standards

 Performance for Equip~ent

Leaks of VOC in the Synthetic Organic Chemicals

~

Manufacturing

 Industry,’ 40 CFR

60,

 Subparts A and VV.

The

Illinois

EPA

administers

the

NSPS

for

subject

sources

Illinois

pursuant

delegation

agreement with the USEPA.

 The Perrnittee shall’comply

with all applicable requirements of 40 CFR 60,

~

Subpart VV and 40 CFR 63,

 Subpart CC.

S

Note:

 Applicability of Subpart VV is triggered

because the refinery

 is subject to the National

Emission Standards for Hazardous Air Pollutants From

Petroleum Refineries,

 40 CFR 63,

 Subparts A and CC

and the Standards of Performance for Equipment Leaks

of VOC in Petroleum Refineries,

 40 CFR 60, Subparts A

and GGG.

 The Permittee has

 indicated that they will

Page

4

comply with the equipment leak requirements specified

in

 40 CFR

63,

 Subpart CC and 40 CFR 60,

 Subpart GGG

by complying with 40 CFR

60,

 Subpart VV.

c.

i.

 This permit

 is issued based upon the caustic

S

 regenerator vent associated with the ELOT

being subject to the National Emission

Standards for Hazardous Air Pollutants From

Petroleum Refineries,

40

 CFR 63,

 Subparts A

and CC.

 The Illinois EPA administers the

NESHAP for subject sources in Illinois

pursuant to a delegation agreement with the

USEPA.

 The Permittee shall comply with all

applicable requirements of

 40 CFR 63,

Subpart CC.

ii.

 The Permittee shall reduce emissions of

organic HAP’s from the caustic regenerator

vent using a flare that meetsthe requirements

of

 40 CFR 63.11(b)

40

 CFR 63~643(a)(1))

1.1.4

 Non-Applicability of Regulations of Concern

a.

 This permit is issued based on the

 F-l Charge Heater

not being subject to 40

 CFR 60 Subpart Db,

 NSPS for

Industrial-Commercial-Institutional Steam Generating

Units because the F-l Charge Heater is not

 a steam

generating unit.

This

permit

issued

based

the

Tier

 2 project not

being subject to NSPS for Standards of Performance

for VOC Emissions From Petroleum Refinery Wastewater

Systems,

 40 CFR 60 Subpart QQQ,

 because no new or

modified individual drain systems will be added as

part of the Tier 2 project.

c.

 The source has addressed

 the applicability and

~

compliance of 40 CFR 52.21,

 Prevention of Signific~rit

Deterioration

 (PSD)

 and 35

 IAC Part 203,

 Major

Stationary Sources Construction and Modification

 (See

Attachment

1).

 The limits established by this permit

are intended

 to ensure that the modification

addressed in this construction permit does not

constitute a major modification pursuant to these

rules.

S

d.

 Compliance with 40 CFR

60,

 Subpart VV shall

 serve

as

the Alternative Program for Leaks

 as allowed by 35

IAC 219.450.

Page

5

1.1.5

 Operational and Production Limits and Work Practices

a.

i.

 The firing rate of the F-l Charge Heater

 shall

not exceed 25.0 mmBtu/hr

 (daily average)

ii.

 The’ quantity of gas burned in the LOT Flare

shall not exceed 58.7 mmscf/yr.

iii.

 Only gaseous fuels shall be burned

 in the

F-l

Charge Heater and the LOT flare.

b.

 This permit

 is issued based on the Boiler 17 firing at

an increase rate

 (additional

 132 mmBtu/hr)

 due to

increased steam demand for the new naphtha splitter

column reboilers

 (T-5032/T-5033).

 Note:

 the Boiler 17

will

 continue to operate within its designed capacity.

c.

 This permit is

 issued based on the alky HM-l heater

firing at an increase rate

 (additional 7.93 mmBtu/hr)

to preheat the feed entering the

 GHT.

 Note:

the

alky HM-l heater will continue to operate within its

designed capacity.

d.

 These requirements,

 and the emission limitations in

Condition 1.1.6, become effective following

completion of

 the Tier

 2 Project when the Refinery

first begins to process low-sulfur gasoline

for

commercial

 sale.

1.1.6

 Emission Limitations

S

a.

i.

 Emissions from the HCNHT F-i Charge Heater

shall not exceed the following limits:

Emi&sions

Pollutant

 (Ton/Mo)

 (Tons/Year)

NO~

 0.90

 10.74

SO2

 0.01

 0.06

CO

 0.76

 9.02

VOM

 0.05

 0.59

PM/PM10

 0.07

 0.82

ii.

 Emissions from LOT flare shall not exceed

the

following limits:

S

Emissions

Pollutant

 (Tons/Mo)

 (Tons/Year)

NO~

 0.29

 2.03

SO2

2.58

18.06

1.58

11.04

VOM

‘

0.60

4.18

Page

6

b..

 Emissions of VOM from the new components

 (i.e.,

valves,

 pumps,

 flanges,

 etc.)

 associated with the

Tier

2

 Project shall not exceed 29.55 tons per year.

This value shall be divided by 12 to calculate

a

monthly emission rate for purposes of Condition

1.1.6(f).

c.

 This permit is issued based upon emissions

S

attributable to the additional steam load

 (required

by naphtha splitter column reboilers T-5032/T-5033)

placed on the Boiler

17

as

 follows:

Emissions

Pollutant

 (Tons/Year)

NO~

 83.03

SO2

 2.89

CO

 47.77

VOM

 3.13

PM/PM10

 4.32

The NO~and

 SO2 emissions shall be calculated using a

continuous emission monitor,

 and the

CO,

PM,

 and VOM

emissions shall be calculated using USEPA emission

factors.

d.

 This permit

 is issued based upon emissions

attributable to the heat input required to preheat

the feed entering the GHT Unit as

 follows:

Emissions

S

Pollutant

 (Tons/Year)

S

NO~

 3.42

SO2

 0.17

CO

 2.87

VOM

 0.19

PM/PM10

 0.26~

S

The SO2 emissions

 shall be calculated using a

continuous emission monitor,

 and the NO~, CO.

PM,

and

VOM emissions shall be calculated using USEPA

•“

emission factors.

S

S

e.

 This permit

 is issued based upon emissions

attributable to the additional sulfur loading placed

the

Sulfur

Plant

follows:

S

Emissions

S

Pollutant

 (Tons/Year)

SO2

6.81

Page

7

Note:

 This emission rate represents the additional

loading to the sulfur plant from both Phase

 1 and

2

of the Tier

 2 project.

f.

 Compliance with annual limits

 shall be determined on

a monthly basis from the sum of

 the data

 for the

current month plus the preceding 11 months

 (running

12 month total)

S

1.1.7

 Testing Requirements

Hydrogen Sulfide Testing

In accordance with 40 CFR 60.8, within 60 days after

achieving the maximum production rate at which the

affected fuel gas combustion devices will be operated, but

not later than 180 days after initial startup of the

affected fuel gas combustion devices and at such other

times

 as may be required by the Illinois EPA,

the

Permittee

 shall conduct performance

 test(s)

 in accordance

with 40 CFR 60.106(e)

 and furnish the Illinois EPA a

written report of

 the results of such performance test(s).

Note:

 The hydrogen sulfide testing requirement is not’~

necessary if

 the H2S content of the fuel gas

 to the

affected heaters

 is monitored by an existing CEM.

1.1.8

 Monitoring Requirements

a.

i.

 The Permittee shall comply with the monitoring

requirements specified in 40 CFR 60.105 for

the affected fuel gas combustion devices by

installing,

 calibrating, maintaining and

operating an instrument for continuously

monitoring

and

recordin~

the

concentration

(dry basis)

 of H2S

 in fuel gases before being

burned in the affected fuel gas combustion~

S

devices.

ii.

 Pursuant to 40 CFR 60.13(i),

 after receipt and

consideration of written application,

 t~he

USEPA may approve alternative monitoring

procedures.

For

the

affected

fuel

gas

combustion

devices,

the

Permittee shall determine compliance with the H2S

standard in 40 CFR 60.104 (a)

(1)

 as follows:

S

Method

11,

15,

l5A,

shall

used

determine

the

H2S

concentration

the

fuel

gas.

The

gases

entering

the

sampling

train

should

about

atmospheric

pressure.

the

pressure

the

refinery

fuel

gas

Page

8

lines

 is relatively high,

 a flow control valve may be

used to reduce the pressure.

If

 the line pressure is

high enough to operate the

 sampling train without a

vacuum pump,

 the pump may be eliminated from the

 sampling train.

 The sample shall be drawn from a

point near the centroid of the fuel gas line

40

CFR

60.106(e) (1).

c.

 For the affected fuel gas combustion devices,

the

Permittee shall maintain records of the concentration

(dry basis)

of

 H2S in fuel gases before being burned

in

 the affected heaters to demonstrate compliance

with Condition 1.1.3(a) (i) (B).

1.1.9

 Recordkeeping Requirements

a.

 The Permittee shall maintain records of the following

items:

Firing

rate

the

 F-i Charge Heater

 (mmBtu/hr

daily

average);

ii.

 The quantity of gas burned in the LOT Flare

(mmscf/month);

iii.

 Steam demand for the naphtha splitter column

reboilers

 (T-5032/T-5033)

 from Boiler

17

(lb/hr.

 daily average);

iv.

 Emissions of NO~, CO, VOM,

 SO2,

 PM and

 PM10

from Boiler

 17 attributable to the additional

steam demand required by the naphtha splitter

column reboilers

 (T-5032/T-5033)

 (tons/month

and tons/year);

S

v.

 Emissions of NO~, CO, VO~, SO2,

 PM and

 PM10

from the alky

EN-i

heater attributable to ~he

increased firing rate required to preheat t~ie

 feed to the GET5 (tons/month and tons/year);

and

vi.

Emissions

NOR,

CO,

VOM,

SO2,

and

 P’M10

from the affected fuel gas combustion de\rices

(tons/month and tons/year).

S

The

Permittee

shall

maintain

records

the

following

items

for

fugitive

emissions

from

components

associated

with

the

Tier

project:

i.

 Number ofnew components by unit or location

and

type

the

Tier

Project;

and

Page

9

ii.

Calculated

VOM

emissions

including

supporting

 calculations,

 attributable to these components

(tons/year),

 based on the methods

 in Condition

 1.1.12(c).

The

Permittee

shall

maintain

records

the

amount

sulfur

attributable

the

Tier

 2 Project

 (Phases

1

and 2)

the

Sulfur

Plant

(long

ton

sulfur/month and long ton sulfur/year)

S

1.1.10

 Reporting Requirements

a.

 The Permittee shall notify the Illinois EPA of

deviations of permit requirements as follows.

Reports shall describe the probable cause of such

deviations,

 and any corrective actions or preventive

measures taken.

S

b.

 For affected fuel gas combustion devices,

the

Permittee shall comply with the reporting

requirements specified in

 40 CFR 60.107(e)

and

(f)

and 40 CFR 60.105(e) (3).

1.1.11

 Operational Flexibility/Anticipated Operating Scenarios

N/A

1.1.12

 Compliance Procedures

S

a.

 Compliance with the particulate matter and carbon

monoxide emission limitations specified in Conditions

1.1.3(a) (ii)

 and 1.1.3(a) (iii), respectively,

is

considered inherent in

 the normal operation of the

F-i

Charge Heater firing refinery fuel gas or natural gas.

b.

i.

 Compliance with the SO2.limits in Condition

1.1.6(a)

 (ii)

 shall be based on the operating

records required by Condition 1.1.9 and the

sulfur or H2S content of refinery fuel gas~as

 monitored in accordance with Condition 1.i~8.

ii.

 Compliance with the emission limits in

Condition

1.1.6(a)

(i)

for

the

F-i

 Charge

Heater shall be based

the

operating

records

required by Condition

 1.1.9 and appropriate

emission factors:

S

Emission Factor

Pollutant

 (Lbs/mmscf)

NO~

100

VOM

5.5

PM/PM10

7.6

SO2

0.6

Page

10

Note:

the

 0.6 lb/mmscf emission factor for

SO2 is appropriate for combustion of natural

 gas; however,

 if refinery fuel gas

 is burned,

S

 emissions shall be calculated using operating

S

 records and the sulfur or H2S content of

the

refinery fuel

 gas.

iii.

 Compliance with the NO~, CO.

 and VOM emission

limits in Condition 1.1.6(a) (ii)

 for the LOT

flare shall be based on the operating records

required by Condition 1.1.9 and appropriate

emission factors:

Emission Factor

Pollutant

 (Lbs/mmscf)

S

376.14

VOM

 142.32

NO~

69.13

Compliance

with

the

 emission limits

 for VOM leaks in

Condition

1.1.6(b)

shall

based

the

recordkeeping requirements

 in Condition 1.1.9(b)

and

applicable standard emission estimate methodology

published by USEPA in “Protocol for Equipment Leak

Emission Estimates”,

 EPA-453/R-95-017

 (November

1995)

Please note that the Permittee should update their CA-APP application to

include this equipment by submitting form 505-CA-APP

 “Supplement to CA-APP

Application”

 along with all other appropriate information.

If you have any questions on this permit, please contact Jason Schnepp at

217/782-2113.

1~7d?t~J~

55

Donald

E.

 Sutton,

 P.E.

Manager,

Permit

Section

Division of Air Pollution Control

DES :JMS

jar

cc:

 Region

3

Attachment

1

PSD Applicability

NO~Netting

Analysis

Contemporaneous-Time

Period

October

1997

 Through October 2002

Table

—

Emissions

Increases

and

Decreases

Associated

With

The

Proposed

S

Modification

83.03

10.74

 3.42

2.03

Total:

99.22

Table II

—

Source-Wide

Creditable

Contemporaneous

Emissibn

Increases

Emissions

Commencement of

 Increase

Item

Equipment

 Operation Date

 (Tons/Year)

 Permit Number

RAU

Deethanizer Reboiler

Proj ect

Table

III

 Source-Wide

Creditable

 Contemporaneous

Emission

Decreases

Commencement of

 Emissions

Operational

 Decrease

Item of Equipment

 Change Date

 (Tons/Year)

 Permit Number

Boiler

(Fuel

Switch)

Boiler

(Fuel

Switch)

DU-2 Mixed Crude Heater West,

F-202

(Fuel

Switch)

DU-2 Mixed Crude Heater East,

F-203

(Fuel

Switch)

CDU

Charge

Heater

Shutdown

DAU

Oil

Heater

Shutdown

DAU Asphalt Solution Heater

Shutdown

RAU

Deethanizer Heater

Shutdown

Item

Equipment

Past

 Future

 Emissions

Actual

 Potential

 Change

(Tons/Yr)

(Tons/yr)

(Tons/Year)

Boiler

Utilization

F-i

Charge

Heater

(Modified)

0.00

Alky

HM-l

Heater

LOT Flare

 0.00

Permit

Number

00120044

00120044

00120044

October 2001

 24.82

01060090

July 1999

July 1999

24.55

36.24

92110025

92110025

May 2000

 17.82

 92110025 ~

May 2000

September 1999

September 1999

20.18

3.25

1.51

92110025

721l0~625

72110625

September

1999

1.80

72110625

October 2001

Total:

19.60

01060090

124.95

Page

2

Table

—

Net

Emissions

Change

(Tons/Year)

Increases

and

Decr~ases

Associated

With

The

Proposed

99.22

Modification

Creditable Contemporaneous Emission Increases

 24.82

Creditable Contemporaneous Emission Decreases

 124.95

 0.91

These

units,

which

have

historically

been

capable

firing

 maximum

capacity,

 will not be

increasing

capacity.

However,

both

units

will

realize

 a quantifiable incremental increase

 in utilization.

STATE OF ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

DIVISION OF AIR

POLLUTION CONTROL

‘

P. 0.

BOX

19506

SPRINGFIELD,

ILLiNOIS 62794-9506

STANDARD

CONDITIONS FOR CONSTRUCTION/DEVELOPMENT

PERMITS

ISSUED BY

THE

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

S

July

1985

The

Illinois

Environmental Protection

Act (Illinois Revised Statutes,

Chapter

111-1/2, Section

1039)

authorizes

the

Environmental

Protection

Agency

to impose conditions

permits

which it issues.

The following conditions

are

applicable

unless susperseded

by special condition(s).

Unless this

permit has been

extended

or it has been voided by

a newly issued permit, this

permit

will expire one

year from the date of issuance,

unless

a continuous program of construction or development

on this project has

started by such time.

The construction or development covered by this permit shallbe done in compliance with applicable provisions of

the Illinois Environmental Protection Act and Regulations

adopted by the Illinois Pollution dontrol Board.

There shall be no deviations from the approved plans and specifications unless a writtenrequest for modification,

along with

plans

and

specifications as required, shall

have

been submitted

to the

Agency and a

supplemental

written permit

issued.

The permittee shall

allow any

duly authorized agent of the

Agency

upon

the

presentation of credentials, at

reasonable times:

to enter the permittee’s property where actual

or potential

effluent, emission or noise sources are located or

where any activity

to be conducted pursuant to this

permit,

S

to have

access to and to

copy any

records required to

be kept under

the terms and conditions of this permit,

to inspect, including during any hours of operation of equipment constructed or operated under

this permit,

such equipment

and any equipment

required to be kept, used, operated, calibrated

and maintained under

this

permit,

S

to obtain

and remove samples of any discharge or emissions of pollutants~,and

to enter and utilize

any photographic,

recording,

testing,

monitoring

or other equipment

for the purpose

preserving,

testing,

monitoring, or recording any

activity, discharge,

emission authorized

by this

permit.

The issuance of this permit:

shall

not

considered

any

manner

affecting

the

title

the

premises

upon

which

t’he

permitted

facilities

are

to be located,

S

S

does not release the permittee

from any liability for damage to person or property caused by or resulting

from

the construction,

maintenance,

or operation of the

proposed facilities,

does not release the permittee

from compliance with other applicable statutes

and regulations

of the United

States,

of the State

of Illinois, or with applicable

local laws, ordinances

and regulations,

does not take into consideration or attest

to the structural

stability

of any

units

or parts of the

project,

and

IL 532—0226

APC

166

Rev.

5/99

PrintedonRecydedpaper

in no manner implies or suggests that

the Agency

(or its officers, agents or employees)

assumes any liability,

directly

indirectly,

for any loss

due

to damage,

installation,

maintenance,

operation

of the

proposed

equipment

or facility.

Unless a joint

construction/operation

permit

has been issued, a permit

for operation

shall be

obtained from

the

Agency before the equipment

covered by

this

permit

placed into operation.

For purposes of shakedown and testing,

unless

otherwise specified

a special permit

condition, the

equip-

ment

coyered under this

permit may

be operated for a period not to

exceed

thirty

(30)

days.

The Agency may

file a complaint

with the

Board

for modification,

suspension or revocation

of a permit:

upon discovery that

the permit

application contained misrepresentations,

misinformation or false statements

or that

all relevant

facts were not disclosed,

upon finding that

any standard

or special

conditions

have been violated, or

upon any violations

of the Environmental

Protection

Act or any regulation effective thereunder as a result of

the construction or development

authorized

by this permit.

STATE

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

DIVISION

AIR

POLLUTION

CONTROL

P.O.

BOX

19506

SPRINGFIELD,

ILLINOIS

62794—9506

STANDARD

CONDITIONS

FOR

 OPERATING PERMITS

May,

1993

The

 Illinois

 Environmental

 Protection

Act

 (Illinois

 Revised

 Statutes,

 Chapter

 111—1/2,

 Section

1039)

grants

the

 Environmental Protection Agency authority to impose conditions

 on permits

 which

it

issues.

S

The following conditions are applicable unless superseded by special permit conditions

(~S)~

The

 issuance

of

 this

permit

 does

not

 release the

 Permittee

 from

 compliance

 with state

and

federal

 regulations which are

 part of the

 Illinois State

 Implementation

 Plan,

 as well

 as with

other applicable statues and regulations

of

 the United States or the State of

 Illinois

 or with

applicable

 local laws,

 ordinances and regulations.

2.

The

 Illinois EPA has

 issued

 this permit

 based upon the information

 submitted by

the

 Pernittee

in the

 permit application.

Any

misinformation,

false

 statement

or

 misrepresentation

in

the

application shall be ground for revocation under

35 Ill.

Adm.

 Code 201.166.

3.

a.

The

 Permittee

 shall

 not authorize,

 cause,

 direct

 or allow

any modification,

 as defined in

35

 Ill.

Adm.

 Code

 201.102,

 of equipment,

 operations

or

practices-which are reflected

in

the

 permit

 application

as

 submitted

 unless

a

 new application

or

 request

for

 revision of

the existing permit

is

 filed with the

 Illinois EPA and unless

 a new permit

 or revision of

the existing permit(s)

is

 issued for such modification.

b.

 This permit only covers

 emission sources and control equipment while physically present at

the

 indicated plant

 location(s).

 Unless

the

 permit specifically provides

for

 equipment

relocation,

 this permit

 is void for an item of equipment on the day it is removed from the

permitted location(s)

 or if all equipment is removed,

 notwithstanding the expiration date

specified on the permit.

4.

 The Permittee shall allow any duly authorized agent of the Illinois EPA, upon the presentation

of credentials,

 at reasonable times:

a.

 To enter

the

 Permittee’s property where

 actual

 or potential

 effluent,

 emission or noise

sources are located or where any activity is to be conducted pursuant to this permit;

b.

To

 have

 access

to

and

to

 copy

any

 records

 required

 to .Me

 kept

 under

the

 terms

and

conditions of this permit;

5

5•

c.

To

 inspect,

 including during any hours of operation of

 equipment constructed oi~operated

under this permit,

 such equipment and any equipment required to be

 kept,

 used,

 operated,

calibrated and maintained under this permit;

S

d.

 To obtain and remove samples of any discharge or emission of pollutants; and

e.

 To enter

 and utilize

 any photographic,

 recording,

 testing,

 monitoring or other

 equipment

for the purpose of preserving,

 testing, monitoring or recording any activity,

 discharge or

emission authorized by this permit.

S

S

5.

 The issuance of this permit:

a.

 Shall

not

 be considered as in any manner affecting the

 title of the premises upon which

the permitted facilities are located;

S

IL

532—0224

5

 090—005

APC

 161 Rev. Mazch,

2001

PRINTED

RECYCLED

PAPER

S

b.

 Does not release the Permittee

 from any

 liability for damage

 to person or property ~

by or resulting from the construction,

 maintenance,

 or operation

of

 the facilities;

c.

 Does not take into consideration or attest to the structural stability of any unit

 or part

of the project; and

d.

In

 no manner

 implies

or

 suggests

 that

the

 Illinois

EPA

(or

its

 officers,

 agents,

or

employees)

 assumes any

 liability,

 directly

or

 indirectly,

for

any

 loss

due

to

 damage,

installation, maintenance, or operation of the proposed equipment or facility.

6.

 The facilities covered by this permit shall be operated in such

 a manner that

 the disposal of

air contaminants collected by

 the equipment shall

 not cause

 a violation of the Environmental

Protection Act or regulations promulgated thereunder.

7.

 The Permittee shall maintain all equipment covered under this permit

 in such a manner that

the

performance of such equipment

 shall not cause

 a violation of the Environmental Protection Act

or regulations promulgated thereuner.

8.

The

 Permittee

 shall

 maintain

a

 maintenance

 record

on

the

 premises

for

 each

 item

of

air

pollution

 control

 equipment.

 This

 records

 shall

be

 made

 available

to

any

 agent

of

the

Environmental Protection Agency at any time during normal working hours and/or operating hours.

As

a

 minimum,

 this

 record

 shall

 show

the

 dates

 of performance

 and nature

 of preventative

maintenance activities.

S

9.

 No person shall cause or allow continued operation during malfunction,

 breakdown or startup of

any

emission

source

 air pollution control equipment if such operation would

 cause a

violation

of

an

 applicable

 emission

 standard

or

 permit

 limitation.

 Should.

a

 malfunction,

breakdown or startup occur which results

in

emissions

 in excess of any applicable standard or

permit limitation, the Pertnittee shall:

a.

 Immediately report

the

 incident to the

 Illinois

 EPA’s

 Regional Field Operations

 Section

Office

by

 telephone,

 telegraph,

or

 other

 method

as

 constitutes

the

 fastest

 available

alternative,

and

 shall

 comply

 with

all

 reasonable

 directives

of

the

 Illinois

 EPA with

respect to the incident;

b.

 Maintain the following records for

 a period of no less than two

(2)

 years:

i.

 Date and duration of malfunction, breakdown,

 or startup,

ii.

 Full and detailed explanation of the cause,

iii. Contaminants5emitted and an estimate of quantity of emissions,

iv.

 Measures taken to minimize

 the amount of emissions during the malfunction, breakdown

or startup, and

S

v.

 Measures taken to reduce future occurrences and frequency of incidents.

13.

 If the permit

application contains

a

 compliance

program and project completion

 schedule,

the

Perrnittee

 shall submit

 a project completion

 status report within thirty

 (30)

 days of ~ny date

specified in the compliance program and project completion schedule or at six month

 intervals,

whichever

 is more frequent.

31.

 The Permittee shall submit an

Annual

Emission Report as required by 35

SIll.

Mm.

Code

 201.302

and

 Ill.

Adxn.

Code

Part

254.

2815C