RCRA permit modifications and the functional equivalency demonstration: A case study

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Description

Hazardous waste operating permits issued under the Resource Conservation and Recovery Act (RCRA) often impose requirements, typically by reference to the original permit application, that specific components and equipment be used. Consequently, changing these items, even for the purpose of routine maintenance, may first require that the owner/operator request a potentially time-consuming and costly permit modification. However, the owner/operator may demonstrate that a modification is not required because the planned changes are functionally equivalent, as defined by RCRA, to the original specifications embodied by the permit. The Controlled-Air Incinerator at Los Alamos National Laboratory is scheduled for maintenance and improvements ... continued below

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16 p.

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Kinker, J.; Lyon, W.; Carnes, R.; Loehr, C.; Elsberry, K. & Garcia, P. May 1, 1996.

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Description

Hazardous waste operating permits issued under the Resource Conservation and Recovery Act (RCRA) often impose requirements, typically by reference to the original permit application, that specific components and equipment be used. Consequently, changing these items, even for the purpose of routine maintenance, may first require that the owner/operator request a potentially time-consuming and costly permit modification. However, the owner/operator may demonstrate that a modification is not required because the planned changes are functionally equivalent, as defined by RCRA, to the original specifications embodied by the permit. The Controlled-Air Incinerator at Los Alamos National Laboratory is scheduled for maintenance and improvements that involve replacement of components. The incinerator`s carbon adsorption unit/high efficiency particulate air filtration system, in particular, was redesigned to improve reliability and minimize maintenance. A study was performed to determine whether the redesigned unit would qualify as functionally equivalent to the original component. in performing this study, the following steps were taken: (a) the key performance factors were identified; (b) performance data describing the existing unit were obtained; (c) performance of both the existing and redesigned units was simulated; and (d) the performance data were compared to ascertain whether the components could qualify as functionally equivalent.

Physical Description

16 p.

Notes

INIS; OSTI as DE96009031

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  • 15. international conference on incineration and thermal treatment technologies, Savannah, GA (United States), 6-10 May 1996

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  • Other: DE96009031
  • Report No.: LA-UR--96-1133
  • Report No.: CONF-960535--1
  • Grant Number: W-7405-ENG-36
  • Office of Scientific & Technical Information Report Number: 231422
  • Archival Resource Key: ark:/67531/metadc668456

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Office of Scientific & Technical Information Technical Reports

Reports, articles and other documents harvested from the Office of Scientific and Technical Information.

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  • May 1, 1996

Added to The UNT Digital Library

  • June 29, 2015, 9:42 p.m.

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  • Feb. 29, 2016, 7:14 p.m.

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Kinker, J.; Lyon, W.; Carnes, R.; Loehr, C.; Elsberry, K. & Garcia, P. RCRA permit modifications and the functional equivalency demonstration: A case study, article, May 1, 1996; New Mexico. (digital.library.unt.edu/ark:/67531/metadc668456/: accessed July 16, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.