ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE . DECEMBER 22 . 2005
* * * * * PCB 2006-113 * * * * *
BEFORE'FIIE ILLINOIS POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
MARATIION ASHLAND PETROLEI!M, LLC
)
Reverse Osmosis Degasitier Unit
)
PCB (16-
(Tax Certification)
PROPERTY IDENTIFICATION NUMBER
)
S1-34-1-21 or portion thereof
NOTICE
TO
:
Dorothy Gunn, Clerk
John S. SvyearimLen
Illinois Pollution Control Board
Marathon Ashland Petroleum
State of Illinois Center
Rclinerv OITice Bmldine
1(111 W . Randolph Street. Suite I 1-500
Robinson, Illinois 62454
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 electronically filed with the Office of
the Pollution Control Board the APPEARANCE and RECOMMENDATION of the
Illinois Environmental Protection Agency, a 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: December 22, 2005
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Telephone: (217) 524-9137
ELECTRONIC FILING, RECEIVED . CLERK'S OFFICE, DECEMBER 22 . 2005
* * * * * PCB 2006-113 * * * * *
BEFOREIIIE ILLINOIS POI J .1 I ION CON"ROI. BO. ARD
APPEARANCE
I hcrchy-
I11C
ntv
.Appcanuicc in thix proceeding on behalf of the Illinois
Lm uonmcntal Protection Aecncv
.
Rcspectlinlly submitted by
.
Rohh H.Iavnum
Assistant Counsel
Date: December 22,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1031 North Grand Avenue East
P.O. Box 19376
Springfield. Illinois 62794-9276
Telephone: (217) 524-9137
OF'FIIE STATE OF ILLINOIS
-LARATHON ASHLAND PF:I ROLL
.\I, I.LC
Reverse Osmosis Degasilicr Unit
)
PROPERTY IDENI'IEIC:AI ION NUMBF:R
51-3-I-1-21 or portion thercol
I
NCB 06-
(fax Ccruficauon)
ELECTRONIC FILING
.. RECEIVED, CLERK'S OFFICE, DECEMBER 22, 2005
* * * * * PCB 2006-113 * * * * *
RECO\INIENDA'IION
NOW COMES the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
("Illinois EPA-), through its attorneys . and pursuant to 35 III. Adm. Code 125 204 of the
ILLINOIS POLUI ION CONTROL BOARD'S ("Board") procedural reeulations
. files
the Illinois EPA's Recommendation in the above-referenced request Ibrla .x certification
of pollution control facilities. In support thereof, the Illinois EPA states as follows
:
On December 30, 2004, 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 . A copy of the
relevant portions of the application is attached hereto . Exhibit A]
.
The applicant's address is as follows
:
Marathon Ashland Petroleum, LLC
Refinery Office Building
Robinson, Illinois 62454
3 .
The pollution control facilities involved in this request are located at the
aforementioned address and consist of the installation of equipment that purportedly
removes carbon dioxide from product water that is sent to the Fluidized Catalytic
Cracking Unit's Wet Gas Scrubber . The equipment is described as a Reverse Osmosis
BEFORE THE ILLINOIS POI .LC FION (-ONTRO1. BOARD
OF THE STATE OF ILLINOIS
MARATI ION ASHLAND PETROLEUM . LLC
)
Reverse Osnlosis Dccasiher Unit
)
PC13 00-
PROPERTY IDENTIFICATION NUMBER
I
)
Ccrufication)
51-34-1-21 or portion thereof ,
)
ELECTRONIC FILING. RECEIVED. CLERKS OFFICE. DECEMBER 22 . 2005
* * * * * PCB 2006-113 * * * * *
I)ee i;ifier, vvhick
cot 1,1,
„I a "set of dhtnhution noz/Ics_ a hlovcci, and a hold In'' tank
.
. .
No nvuhstandmg the Iunited antnunt
01
tnlo1 -nlauon contained within the application for
tax ccitilication, it does not appear that the overall project . oreecn portions thcrcol,
reduces or eli munucs air pollution . Rathei . it supply prepares water for a line gas
scrubber: it is the latter nluipnteni that actually erfin,ns the function Hair pollution
control. I he description of the
pro
ect sugscsts that it was Intended solely as a pmcess-
elated Improvement . It a also noted that carbon dioxide is not a regulated air pollutant
under either the federal C' lean Air Act or the Illinois Environmental Protection Act
.
4 .
Section I 1-10 of the proper v Tux Coda 35 ILLS 200 1 I-10
( 2_0112) .
defines *'I)()IIL[tion control hiCilities" as
:
''any system_ method, construction, device or appliance appurtenant
thereto, or ally portion of any building or equipment, that is desi2 ned,
constructed, installed or operated liar the primary purpose of : (a)
eliminating, preventing, or reducing air or water pollution
.
. . Or (b)
treating, pt'etreatine, 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 ."
5
.
Pollution control facilities are entitled to preferential tax treatment, as
provided by 35 ILLS 20(1/1 I-5 (2002)
.
6 .
Based on information in the application, it is the Illinois EPA's
engineering judgment that the described project and/or equipment may not be considered
as ''pollution control facilities" in accordance with the statutory definition and consistent
with the Board's regulations at 35 III. Adm. Code 125 200. Exhibit BI .
Because the Reverse Osmosis Degasifier project does not satisfy the
aforementioned criteria, the Illinois EPA recommends that the Board deny the applicant's
requested tax certification
.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE. DECEMBER 22, 2005
* * * * * PCB 2006-113 * * * * *
Respectfully submitted bv,
ILLINOIS ENVIRONMENTAL PRO"I FCTION
AGENCY
Robh Fl. Lnvmai
Assistant Counsel
DATED: December
2
2
004
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
10'_1 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Telephone: (217) 524-9137
ELECTRONIC FILING. RECEIVED, CLERK'S OFFICE, DECEMBER 22 . 2005
* * * * * PCB 2006-113 * * * * *
CERTIFICA I E OF SERVICE
I hereby certify that on the 22 0 day ofDecemher_ 2(105, I electronically filed the
(ollotvinc instruments entitled NOTICE, APPFARANCE and RECOMIMIENDA ZION
kith
:
Dorothy Gtinn, Clerk
Illinois Pollution Control Board
100 West Randolph Street
Suite I 1-500
Chicago . Illinois 00601
and. lurthcr. that I did send a true and con
-ect eopv of the same foregoing instruntents, by
First (lass Mail kith postage thereon Billy paid and deposited into the possession of the
United States Postal Service, to
:
Steve Santarelli
lohn S. Swcaringen
Illinois Department of Revenue
Marathon Ashland Petroleum
I(11 West Jcfllrson
Refinery Office Building
P.O. Box 19033
Robinson, Illinois 62454
Springfield, Illinois 62794
si
Robb H. Layman
Assistant Counsel
ELECTRONIC FILING. RECEIVED, CLERK'S OFFICE, DECEMBER 22. 2005
* * * * * PCB 2006-113 * * * * *
CI-33dnt_g4s
IL 532-0222
APC 151 (Rev. 8100)
Ttu Cengiication for Pollution Control Facilities
Page 1 of 2 .
8/00
-
E
A , 5t1'
,4
APPLICATION FOR CERTIFICATION (PROPERTY TAX TREATMENT)
POLLUTI N CONTROL FACILITY
AIR
WATER
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
P. O. Box 19276, Springfield. IL 627949276
hiss
Agency is aurhmrzcrl m rrgocss this
information undo Illmms Rcnsed
Sire,,,, 1979,
Chaptcr120,Sc Scion501e5.Disclmrrcnfu's
nn`orrrutron
11 1o111-tty
.
If051eVCr,
Isil
Ire 1.
comply could pwvmt your
application
from
being procesud
or
could result in dmial of your
application for ccnigcation.
FOR AGENCY USE
File No.
Date Received
Certification No .
Date
Sec A
Company Name
Marathon Ashland Petroleum LLC
Person Authorized to Receive Certification
Person to Contact to Additional Details
John Swearinqen
Ddnnis Baker
Street Address
Street Address
Refinery Office Buildinq
539 South Main Street
Municipality, State & Zip Code
Municipality, State & Zip Code
Robinson, IL 62454
Findlay OH 45840
Telephone Number
Telephone Number
618-544 2121
41q-471-37_52-
Location of Facility
Muniopaliry
Township
Quarter Section
Township
Range
Robinson
Robinson
Street Address
County
Book Number
Route 33
Crawford
Property Identification Number
Parcel Number
Part of 51-34-1-21
Sec B
i n
4
0
Nature of Operat ons Conducted at he Above Location
Petroleum Refining
Reverse Osmosis Degasifier
Water Pollution Control Construction Permit No
.
Date Issued
NPDES PERMIT No
.
IL-000-4073
Date Issued
Expiration Date
Air Pollution Control Construction Permit No
.
Date Issued
Air Pollution Control Operating Permit No
96010007 (Title V)
Date Issued
Sec C
F
N
a
o
7d
F
Describe Unit Process
See Attached
Materials Used in Process
See Attached
DEC 3 0 2004
EPA
- DAPC
- SPFLD
Sec D
0'6
a4
Describe Pollution Abatement Control Facility
See Attached
ELECTRONIC FILING, RECEIVED. CLERKS OFFICE . DECEMBER 22 . 2005
* * * * * PCB 2006 -113
Tar Ccrnjcanon for Pollution Control Focilinex
Page 2
of
2
8100
Sec. E
z
u
z
i (1) Nature of Contaminants or Pollutants
Carbon
Dioxide
_
,
Material Retained, Captured or Recovered
Contaminant or Pollulan
_
DESCRIPTION
DISPOSAL_OR USE
Carbon Dioxide
co
_
_
(2)
Point(s) of Waste Water Discharge0/p
Fq)uipmpnt Pint Plan
Plans and Specifications Attached
Yes XX
No
(3)
Are contaminants (or residues) collected by the control facility?
Yes
XX
No
(4)
Date installation completed
1995
status of installation on date of application
100%
_
(5)
a
FAIR CASH VALUE IF CONSIDERED REAL PROPERTY:
$
2 c} ZS 00o
b
NET SALVAGE VALUE IF CONSIDERED REAL PROPERTY
:
$
3
(
3 17
s
c
PRODUCTIVE GROSS ANNUAL INCOME OF CONTROL FACILITY
:
$
Z a
d
PRODUCTIVE NET ANNUAL INCOME OF CONTROL FACILITY
:
$
7~4a
e
PERCENTAGE CONTROL FACILITY BEARS TO WHOLE FACILITY VALUE
:
%
1t
)
Sec. F
The following information is submitted in accordance with
knowledge, is true and correct_ The facilities claimed
Illinois Property Tax Code,
,c.Itcw.~c,a
the Illinois Property Tax
herein are 'pollution control
1v1291riy
Code, as amended, and to the best of my
facilities" as defined in Section 11-10 of the
Division Manager
Signature
John Swearingen
Title
Illinois Refining
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
wafer operations are related, file two applications. If attachments are needed, record them consecutively on an index sheet.
Sec A
Information refers to applicant as listed in the tax records and the person to be contacted for further details
or
for
inspection
of
facilities. Define facility location by street address or legal description . A plat map location is required for faotities located
outside of municipal boundaries. The property Identification number is required
.
Sec B
Setf.e%planatory. Submit copies of all permits issued by local pollution control agencies .
(e.g. MSD Construction Permit)
Sec C
Refers to manufacturing processes or materials on hich pollution control fad ity is used
.
Sec D
Narrative description of the pollution control facility, indicating that its primary purpose is to eliminate, prevent or reduce pollution
.
State the type of control facl ty . State permit number, date . and agency issuing permit A narrative description and a process
low diagram describing" pollution control facility . Include a fisting of each major piece of equipm nt included in the claimed
fair cash value for real property . Include an average analysis of the influent and effluent of the control facility stating the
collection efficiency
.
v,
Sec E
List air contaminants, or water pollution substances released as effluents to the manufacturing processes . List also the final
p
disposal of any contaminants removed train the manufacturing processes .
z
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 dearly show (a) Point(s) of discharge to receiving stream, and (b) Sewers and process piping to and from the control
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 sale or reuse of the collecled substances. State the cost of reclamation and related expense
.
Item (4)-Slate the date which the pollution control facility was first placed in service and 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
.
Sec. F
Self-explanatory. Signature must be a corporate authorized signature .
Submit to:
Attention :
Attention :
minds EPA
Thomas McSwiggin
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
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 22, 2005
* * * * * PCB 2006-113 * * * * *
Section C
Describe Unit Process :
The Reverse Osmosis Degasifier consists of a set of distribution nozzles, a blower, and a
holding tank. It removes carbon dioxide from reverse osmosis product water to be sent to
the Fluidized Catalytic Cracking Unit Wet Gas Scrubber for seal water and sump make-
up. The carbon dioxide is removed to increase the pH of the water before piping it across
the refinery
.
Section C
Materials used in process:
Product Water
Ashland Drewcor 2130 Corrosion Inhibitor
Ulrich Sodium Hypochlorite 12.5%
Section D
Pollution Control Facility Description
The Reverse Osmosis unit was added as a pretrcater, ahead of the deionization system
within the Boiler Feed Water Treatment System .
The Reverse Osmosis Degasifier consists of a set of distribution nozzles, a blower, and a
holding tank . It removes carbon dioxide from reverse osmosis product water to be sent to
the Fluidized Catalytic Cracking Unit Wet Gas Scrubber for seal water and sump make-
up. The carbon dioxide is removed to increase the pH of the water before piping it across
the refinery .
Drawing :
R.O. Building Equipment Arrangement Plan
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 22, 2005
* * * * * PCB 2006-113 * * * * *
16
I
.x
Ih
t
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE. DECEMBER 22 . 2005
* * * * * PCB 2006-113 * * * * *
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NnRn .I (, ,r+, Av'oFAST, P.U . H s 1'I ,n I, .
S'
•R
i i
•m
il(',I ulIo .S 627L4.95UG-t 21
.%)
7)s2-_''' I
KI 0 K . 1li,'v .oIEVJCH, GOVrRN(,is
1)OL.GLvS P . XOrr, DIRECTOR
Memorandum
Technical Recommendation for Tax Certification Denial
Date
:
October 27, 2005
To :
Robb Layman
From
:
Don Sutton W ti
C
Subject :
Marathon Ashland Petroleum LLC TC-04-30-12D
This Agency received a request on December 30, 2004 from Marathon Ashland Petroleum LLC for an
Illinois EPA recommendation regarding tax certification of air pollution control facilities pursuant to 35 III
.
Adm, Code 125 .204. I offer the following recommendation .
The air pollution control facilities in this request include the following
:
Reverse Osmosis Degasifier unit whose primary purpose is to reduce C02
from the Fluidized Catalytic Cracking Unit Wet Gas Scrubber . Because the primary
purpose isn't the reduction of Air Pollution and it does not meet the definition of a
"Pollution Control Facility" it is therefore denied because CO2 is not a regulated Air
Contaminant .
This facility is located at 100 Marathon Avenue, Robinson
The property identification number is Part of 51-34-1-21
Based on the information included in this submittal, it is my engineering judgement that
the proposed facility may not be considered "Pollution Control Facilities" under 35 IAC
125.00(a), with the primary purpose of eliminating, preventing, or reducing air pollution,
or as otherwise provided in this section, and therefore not eligible for tax certification
from the Illinois Pollution Control Board . Therefore, it is my recommendation that the
Board deny the requested tax certification for this facility
.
t
~C~~si~ J
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