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Marathon Ashland Petroleum Refinery Air Information Reporting System (RAIRS) Project

This XL project will implement use of The Refinery Air Information Reporting System (RAIRS) at the Marathon Ashland Petroleum LLP's Texas City petroleum refinery. RAIRS is an alternative air information reporting system that was initiated under the Common Sense Initiative to streamline the reporting of air information for Petroleum Refineries.

The RAIRS reporting methodology was developed by incorporating the elements listed in Table 1 below into a reporting system that reduces the costs, manpower and paperwork burden necessary for petroleum refineries to comply with Federal (EPA) and State (TNRCC) air reporting requirements. Implementation of the RAIRS system also reduces the paperwork and manpower burdens for the receiving agency (TNRCC) and will provide the public with improved access to regulatory reports.

# Element Description
1 Report Consolidation For situations where more than one set of reporting regulations (for example, TAC, New Source Performance Standards [NSPS], National Emissions Standards for Hazardous Air Pollutants [NESHAPS], or Maximum Achievable Control Technology [MACT]) are applicable to the same emission point (for example, tanks, fugitives, or wastewater treatment operations), recommendations for consolidation of these reporting requirements will be developed.
2 Report Format Currently, very few reports have a recommended format for submitting; therefore, free form letter submittals are most prevalent. Recommendations for a simplified, more efficient reporting format will be developed based upon experience in report preparation and report consolidation recommendations.
3 Report Value The usefulness of the reported information to regulatory agencies, industry, and the public will be evaluated.
4 Report Classification Evaluate the benefits of separate routine, periodic, and episodic reports
5 Reporting Schedule To ease the regulatory agency's burden for report review, a revolving report submittal schedule for petroleum refineries in Texas in conjunction with suggested modifications to the existing reporting frequency should be developed so that similar reports will be received by the agencies at the same time.
6 Public Access to Reports Public input will be solicited on (1) report consolidation, (2) report format, and (3) report value in order to identify ways to make the information more usable and accessible. The use of communication tools, such as the Internet, will also be evaluated.

The RAIRS project proposes to streamline the quarterly, semiannual, annual, variable and one time reporting requirements for Texas City Refinery's 227 air reports for the following categories:

1. Storage tanks 2. Fugitive emissions
3. Wastewater streams 4. Marine and barge loading
5. Miscellaneous process vents 6. Compliance Assurance Monitoring
7. Chemical accident preventions 8. Facility wide..

Project Correspondence
Federal Register Notices
Final Project Agreement
Evaluation Documents
Other Information

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