(23c) Developing An EMS to Track Compliance with MSS Activities

Texas now requires New Source Review (NSR) permit holders to amend their NSR air permits to include emissions from routine and planned Maintenance, Startup, and Shutdown (MSS) actvities. MSS activities include emissions from shutting down or starting up a chemical process unit. They also include emissions from degassing columns, process vessels, pumps, and storage tanks.

This presentation will cover the development os a computerized Environmental Management System to allow a permit holder to document MSS activities and the emissions that result so that compliance with the permit emission limits can be shown to an agency inspector.