Resource Conservation and Recovery Act 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 that specific components and equipment be used. Consequently, changing these items, 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.`` The Controlled-Air Incinerator at Los Alamos National Laboratory is scheduled for maintenance and improvements. The incinerator`s carbon adsorption unit/high efficiency particulate air filtration system, was redesigned to improve reliability and minimize maintenance. A study was performed to determine whether the redesigned ... continued below

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11 p.

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

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Description

Hazardous waste operating permits issued under the Resource Conservation and Recovery Act (RCRA) often impose requirements that specific components and equipment be used. Consequently, changing these items, 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.`` The Controlled-Air Incinerator at Los Alamos National Laboratory is scheduled for maintenance and improvements. The incinerator`s carbon adsorption unit/high efficiency particulate air filtration system, 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. In this case, the key performance data included gas residence time and distribution of flow over the activated carbon. Because both units were custom designed and fabricated, a simple comparison of manufacturers` specifications was impossible. Therefore, numerical simulation of each unit design was performed using the TEMPEST thermal-hydraulic computer code to model isothermal hydrodynamic performance under steady-state conditions. The results of residence time calculations from the model were coupled with flow proportion and sampled using a Monte Carlo-style simulation to derive distributions that describe the predicted residence times.

Physical Description

11 p.

Notes

INIS; OSTI as DE96005604

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  • Waste management `96: HLW, LLW, mixed wastes and environmental restoration - working towards a cleaner environment, Tucson, AZ (United States), 25-29 Feb 1996

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  • Other: DE96005604
  • Report No.: LA-UR--95-4272
  • Report No.: CONF-960212--6
  • Grant Number: W-7405-ENG-36
  • Office of Scientific & Technical Information Report Number: 204685
  • Archival Resource Key: ark:/67531/metadc669733

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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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  • February 1, 1996

Added to The UNT Digital Library

  • June 29, 2015, 9:42 p.m.

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  • Feb. 29, 2016, 7:20 p.m.

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Elsberry, K.; Garcia, P.; Carnes, R.; Kinker, J.; Loehr, C & Lyon, W. Resource Conservation and Recovery Act permit modifications and the functional equivalency demonstration: a case study, article, February 1, 1996; New Mexico. (digital.library.unt.edu/ark:/67531/metadc669733/: accessed November 22, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.