Paper: (2014025)MAINTENANCE START-UP AND SHUTDOWN (MMS): WHO? WHAT? WHEN? WHERE? WHY? AND HOW TO DEAL WITH IT

As of January 5, 2014, all planned maintenance start-up and shutdown (SMSS) must be accounted for and permitted. TCEQ has also had an effective policy change in what is regarded as MSS and may now consider events related to MSS as Alternative Operating Scenarios (AOS). This paper explores the difference in planned vs. unplanned MSS, when it needs to be reported, when and where it must be reported to, and how to properly plan for complying with the regulatory requirements regarding MSS and associated concerns.