BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

NOTICE
RECOMMENDATION

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

MARATHON ASHLAND PETROLEUM, LLC

)

Continuous Emissions Monitoring System

PROPERTY IDENTIFICATION NUMBER

)

51-34-1-21 or portion thereof

NOTICE

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

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 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

Robb H. Layman

Assistant Counsel

Date: January 4, 2007

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

P.O. Box 19276

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

)

Continuous Emissions Monitoring System

PROPERTY IDENTIFICATION NUMBER

)

51-34-1-21 or portion thereof

)

APPEARANCE

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

Environmental Protection Agency.

Respectfully submitted by,

/s/ Robb H. Layman

Robb H. Layman

Assistant Counsel

Date: January 4, 2007

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

P.O. Box 19276

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

)

Continuous Emissions Monitoring System

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

grant

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. 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

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

is 51-34-1-21.

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

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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 Continuous Emissions

Monitoring System that will be installed on the common stack of two Reactor Heaters for

the Ultraformer Unit, designated as units 3F-1 and 3F-2. The monitoring system will

enable the refinery to continuously monitor emissions of nitrous oxides from the heaters,

thereby increasing the response time for making needed changes to affected equipment

and reducing resulting emissions. Continuous emissions monitoring equipment is an

integral part of an emission source’s overall air pollution control strategy.

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

Continuous Emissions Monitoring System 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.

[Exhibit B].

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

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Because the Continuous Emissions Monitoring System satisfies the

aforementioned criteria, the Illinois EPA recommends that the Board

grant

the

applicant’s requested tax certification.

Respectfully submitted by,

/s/ Robb H. Layman

Robb H. Layman

Assistant Counsel

DATED: January 4, 2007

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

Telephone: (217) 524-9137

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

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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

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

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

P.O. Box 19033

Robinson, Illinois 62454

Springfield, Illinois 62794

/s/ Robb H. Layman

Robb H. Layman

Assistant Counsel

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

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IL 532-0222

APC

15

(Rev.

8/00) 

APPLICATION FOR CERTIFICATION (PROPERTY TAX TREATMENT)

POLLUTION CONTROL FACILITY

AlRa

WATER

canlply could prevent 

your

application 

from

application for cenification. 

Refinery Office Building          

539

South Main Street 

Ultraformer 

3F-1 

and

3F-2 

CEMs 

Tar

CeniJcolionfor Pollurion Conrrol Fmililier

Sec. C

I

Sec.

UF

5%

Q$

Air Pollution Control Operating Permit No.

96010007

(Title 

V

Permit) 

Date Issued

November 

24, 2003 

Describe Unit Process

The Ultraformer charge consists of hydrotreated naphtha which combines with hydrogen 

gas as it enters the preheat exchangers. The naphtha then enters a series of heaters 

and reactors, which upgrade the naphtha's octane. 

3F-1 

and

3F-2 

are two of the heaters. 

Materials Used

in

Process

Naphtha 

Hydrogen 

Fuel gas 

Describe Pollution Abatement Control Facility

In order to reduce IRD's overall combustion source NOx emissions, a Continuous Emissions 

Monitoring 

(CEM) System for NOx will be installed on the common stack of the Ultraformer 

reactor heaters 

3F-1 

and

3F-2. 

At the time of this application, the nozzles for the 

CEMs have been installed to facilitate the installation of the CEMs in 

2008. 

The

Ultraformer operates under the Title 

V permit No. 

96010007. 

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

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Tar

Cerii/ienrion/or Pollurior~ Cor!rrol Focililier

Page 2 0/2

8/00

Illinois Refining Division 

z

P

0

General: Separate applications must be completed for each mntml facility claimed. Do not mix types (water and air). Where both air and

0

Sec. E

Sec. F

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

Information refers to applicant as listed in the tax remrds and the person to be mntaded for further details or for inspedion 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 wpiesof all permits issued by local pollution mntrol 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

ib primary purpose is to eliminate, prevent or reduce pollution.

Stale the type of

wntrol facility. State permit number, date, and agency issuing permit. A narrative description and a process

flow diagram describing the

Dollution mntrol facilik. lndude a listing of each major piece of equipment included in the daimed

fair cash value for real property.

lndude an

analysis of the influent and

emuen! of the mntrol facility stating the

collection efficiency.

List air mntaminants, or water pollution substances released as effluents to the manufacturing processes. List also the final

disposal of any mnlaminants removed from the manufacturing processes.

ltem

(1) -Refers to pollutants and mntaminants removed from the process by the pollution mntrol facility.

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

which clearly show (a)

Point@) of discharge to receiving stream, and (b) Sewers and process piping to and from the mntml

facility.

llem

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

in dollars reclaimed by sale or reuse of the

mlleckd substances. State the wst of reclamation and related expense.

llem (4) -State the date which the pollution wntrol facility was first placed in service and operated. If not, explain.

ltem

(5) -This information is essential lo 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.

Division of Water Pollution Contml

Division of Air Pollution Control

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

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ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

I021

NORTH

GRAND AVENUE EAST,

P.O.

BOX

19506,

SPRINGFIELD,

ILLINOIS

62794-9506

- (

21 7) 782-21 13

ROD R. BLACOIEVICH,

GOVERNOK DOUGLAS

P. SCOTT, DIRECTOR

Memorandum

Technical Recommendation for Tax Certification Approval

Subject: Marathon Ashland Petroleum LLC TC-05-12-29C

This Agency received a request on December 29, 2005 from Marathon Petroleum Company LLC for an

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

111.

Adm. Code 125.204. 1 offer the following recommendation.

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

Continuous Emission

Monitors(CEM) whose primary purpose is to monitor and

allow the reduction of

NOX emissions generated in the heaters. 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 51-34-1-21

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,

or 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.

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

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