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The Permit Protection Myth

Publisher: Catalytic Products International
Overview:
Discussing about the risks and liabilities of emission unit operators, this paper details some of the factors that are applicable to operators who are using catalytic and thermal oxidizers as emission control devices. The paper states that the operators are required to comply with all applicable regulations and laws, even though they are not mentioned in the permit document, and presents the drawbacks of Title V operating permit. It explains why EPA typically chooses temperature rise as the appropriate compliance indicator for the units which are using catalytic oxidizers as VOC controller. Briefly explained are the failures and penalties of catalyst, heat exchanger, regenerative thermal oxidizer valve and cold face along with illustrations. The paper suggests that it is important to test regenerative thermal and catalytic oxidizers at least once in a year.
TABLE OF CONTENTS
1.Introduction3
2.The Myth of Permit Protection3
3.Permit Compliance Indicators4
4.Catalyst Failures4
5.Heat Exchanger Failures5
6.Regenerative Thermal Oxidizer Valve Failures7
7.Regenerative Thermal Oxidizer Cold Face Failures8
8.Conclusion and Resources8
9.Figures
9.1.Failure of a Typical Shell and Tube Expansion Joint6
9.2.Example of Extreme Heat Exchanger Failure6
9.3.Typical Regenerative Butterfly Valve Platter and Seat7
9.4.Regenerative Thermal Oxidizer Ceramic Media Bed Failure8
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