Jim Woodford has a B.S. in Natural Systems with an emphasis in
Biology.
He also possesses an M.S. in Biology with environmental course work
concentration.
He is a certified Hazardous Materials Manager (CHMM) at the Master
level
as bestowed by the Institute of Hazardous Materials Management in
Rockville,
MD. He is also a certified Mine Safety Health Administration (MSHA)
instructor.
He has served as Waste Fuels Chemist, Laboratory Manager, Facility
Manager
and Site Manager at the operating plant level. He also served as a New
Facility Project Coordinator and a Recruiting Director for a national
waste
processing company at the corporate level. Additionally, he served as
Director
of Operations for a specialty chemical manufacturer with international
distribution.
Specific experience includes the following:
- Wrote and presented paper entitled "Risk Management Plan
Update and
Modification" at the 1999 Air and Waste Management Association
Hazardous
Waste Combustor Specialty Conference.
-
Provided emissions testing on-site oversight for a West Texas
combustion
device.
-
Collaborated on and co-authored a preliminary emissions testing
plan
for a West Texas combustion device with the intent of determination of
initial compliance status.
-
Co-authored and collated review of the signed, pre-publication
EPA regulation
entitled, "NESHAPS: Final Standards for Hazardous Air Pollutants for
Hazardous
Waste Combustors."
-
Collaborated on the writing and publication of the Gossman
Consulting,
Inc. Portland Cement NESHAP/MACT Notebook sold commercially as a
compliance
aid.
-
Drafted and provided review of subsequent drafts of a
dioxin/furan testing
plan for a Missouri combustion device.
-
Provided review and comment for a Draft Risk Assessment Work
Plan for
a waste fuels facility in Indiana.
-
Reviewed draft Region V and Region VII quality assurance project
plans
for current version of test methods including (but not limited to)
SW846
0010, 0040, 0051, 0060, 1311, 8260B, 8270C, 8290X and SW846-9056. Also
included in this review were methods for particle size distribution;
CARB
501, non-volatile organics gravimetric determination; GRAV, and total
organics
measurement TOE.
-
Drafted and co-authored a Part B test plan, including a detailed
quality
assurance project plan (QAPP), for an Indiana combustion device.
-
Drafted and co-authored a RCRA emission test plan, including a
detailed
quality assurance project plan (QAPP), for an Indiana combustion device
in order to comply with the boiler and industrial furnace regulations.
-
Provided text and overall collation of major revision of the
waste analysis
plan, in response to EPA comments, for a Northern Indiana combustion
device,
as part of their Part B permitting efforts.
-
Help to perform RCRA/BIF audits for company internal use at two
US TSDFs.
-
Researched and pulled together various required forms and
applications
for permitting new waste fuels tank at a TSDF in the state of Indiana/
USEPA Region V.
-
Coordinated annual filing of CKD landfill permitting related
report
for an Illinois cement manufacturing facility; 1992 - 1998.
-
Researched and reported findings concerning requirements of
40CFR Part
63 Subpart DD - National Emission standards for Hazardous Air
Pollutants
from Off-Site Waste and Recovery Operations.
-
Reviewed and provided client comments for CKD landfill
regulations being
developed in the state of Indiana.
-
Provided client comment responses and comment response support
for adjudicated
permit hearing in Texas.
-
Performed Southeast US landfill material acceptance and cost
research
and analysis for industrial client.
-
Reviewed 28 emissions reports for various plant locations
throughout
the United States for major US cement manufacturing company. Test
reports
were reviewed for data quality and assessment of future testing needs.
-
Provide review and comment on refractory brick management
program at
hazardous waste burning cement kiln in Southeast US/Region IV.
-
Research and provide recommendations concerning EPCRA Section
304 and
CERCLA Section 103, reporting continuous releases of hazardous
substances.
-
Perform research resulting in a reference report on nonmetal
constituents
of concern as per 40CFR 266.112 in regards to hazardous waste burning
cement
kilns "residues" management. Review included three cement plants of
major
US cement manufacturer.
-
Attended Peer Review Meeting for EPA’s Inventory of Sources of
Dioxin
in the United States as announced in 4-27-98 Federal Register.
-
Attended A&WMA 1998 specialty conference, Waste Combustion
in Boilers
and Industrial Furnaces. Presented paper entitled, "An Analysis of
Selected
NOD Issues Related to Waste Analysis Plans." Compiled a conference
summary
report.
-
Reviewed and provided client comments on "The Inventory of
Dioxin in
the United States" as revised by USEPA in 1998.
-
Provided on-sight oversight for Recertification of Compliance
testing
for Indiana hazardous waste combustion device.
-
Drafted and collated final compliance test plan, including
detailed
QAPP, for Indiana combustion device.
-
Reviewed the proposed non-hazardous waste burning cement kiln
MACT,
along with "supporting" documentation to provide recommended comments
to
industry organization focusing on mercury and dioxins.
-
Provided review and response to EPA permit review comments for
Missouri
hazardous waste combustion device.
-
Attended 1997 A&WMA specialty conference, Waste Combustion
in Boilers
and Industrial Furnaces. Presented paper entitled, "Continental Cement
Trial Burn Strategy Follow-up." Co-authored paper entitled, "A Model
Waste
Analysis Plan for Commercial BIF Facilities." Compiled a conference
summary
report.
-
Reviewed and provided comment/compliance recommendations
concerning
USEPA Proposed Effluent Limitations Guidelines and Pretreatment
Standards
("effluent guidelines") for the Industrial Waste Combustor Sub-category
of the Waste Combustors Point Source Category (63 FR 6391).
-
Conducted client research on HCl continuous emission monitors
for combustion
device.
-
Provided review and comment response to UK combustion comments.
-
Performed K088 client research for disposal options
determination.
-
Performed three facility/three state review of facility SOPs for
determination
of inter-facility standardization for industrial chemical company.
-
Researched used oil/filter fluff as alternative fuel for use in
a non-hazardous
combustion device in Illinois.
-
Provided review and recommended response to regional regulatory
comments
for Missouri waste combustor.
-
Help to develop a web site for Missouri manufacturer and waste
combustion
device.
-
Provided review and recommended response to regional regulatory
comments
concerning facility waste analysis plan for Missouri hazardous waste
combustor.
-
Perform regulatory emissions review and testing oversight for
Canadian
manufacturer and waste combustion device.
-
Perform review and provide client comment recommendations for
USEPA
trial burn guidance document.
-
Researched waste plastic as alternative fuel for use in a
non-hazardous
combustion device in Illinois.
-
Attended Fifth International Congress on Toxic Combustion
By-products
at the University of Dayton.
-
Review draft risk assessment and provide comments for Missouri
waste
combustion device.
-
Research benzene NESHAP agreement and provide compliance
recommendations
for Indiana manufacturer and waste combustor.
-
Review and provide comment on USEPA Notice of Data Availability
for
hazardous waste combustor proposed rule.
-
Attended 1996 A&WMA specialty conference, Waste Combustion
in Boilers
and Industrial Furnaces. Presented paper entitled "A Comparison of
Normal
and Worst Case Cement Plant Emissions." Compiled a conference summary
report.
-
Attended USEPA dioxin sources workshop as part of the finalizing
of
the USEPA dioxin reassessment.
-
Co-authored regulatory inquiry response concerning the burning
of waste
solvents in cement kilns in the United Kingdom.
-
Performed waste analysis plan review and update.
-
Provided review oversight of Region VII BIF Trial Burn Report.
-
Reviewed and provided comment on the proposed Hazardous Waste
Combustor
regulations.
-
Provided compliance test plan review and on-site process
sampling QA/QC
for Canadian Cement kiln test burn.
-
Process sample manager for two part Trial Burn in Region VII.
-
Presented normal and worst case metals emission data and
co-authored
published results.
-
Reviewed incinerator waste analysis plan in comparison to BIF
requirement
then presented and published findings.
-
Conducted annual RCRA/BIF audits for internal client use.
-
Provided on-site oversight for Region III tire burn.
-
Performed Region V BIF Trial Burn Plan review and comment.
-
Provided QA/QC review of multiple Trial Burn and compliance test
data.
-
Drafted and submitted a Recertification of Compliance Test
report.
-
Was Project Manager for a 1995 Recertification of Compliance
Test in
Region V.
-
Interacted with Region V and Region VII personnel on compliance
test
modifications.
-
Was Project manager for a 1995 Trial burn Test in Region VII.
-
Drafted and submitted trial burn test results.
-
Assisted in metals spiking for a Region VII trial burn test.
-
Reviewed and provided comments on Subpart CC regulations on air
emissions
controls.
-
Worked with state level fugitive dust regulations.
-
Co-author of Understanding Dioxin Testing manual.
-
Co-authored external QA/QC document for compliance test.
-
Updated a RCRA Part B and Operations Manual.
-
Wrote Hazardous Air Pollution (HAP) Test Plan for a Midwestern
cement
kiln.
-
Was Project Manager for a HAP test at a cement kiln.
-
Drafted SPCC plan for cement terminal.
-
Worked with Indiana and Illinois CKD disposal regulations.
-
Assisted in metals spiking for Region IX BIF compliance test.
-
Worked with state and federal Clean Air Act Permit Programs
(CAAPP).
-
Editor of Cement and Waste Materials Conversion News, a monthly
newsletter.
-
Primary author of 1995 A&WMA BIF Conference paper entitled
"The
Effect of Process Differences on System Removal Efficiencies (SREs) and
the Fate of Metals in Cement Kilns".
-
Authored and presented 1994 Air & Waste Management
Association BIF
Conference paper entitled "EPA Regional Variances in the Interpretation
and Implementation of the BIF Regulations".
-
Authored white paper on dioxins and cement kilns.
-
Primary reviewer and author of a set of comments on the EPA
Dioxin Reassessment.
-
Worked with state level CKD landfill regulations.
-
Reviewer and primary author of a set of comments on the EPA
Combustion
Emissions Technical Resource Document (CETRED).
-
Drafted and submitted BIF Recertification of Compliance Trial
Burn Test
Plan, which included "data in lieu of".
-
Helped plan and participated in dioxin emission testing at
several Midwest
kilns.
-
Developed response file for EPA Waste Analysis Plan (WAP)
inspection
checklist.
-
Drafted and submitted a Trial Burn Plan for a Region VII BIF.
-
Drafted and submitted Trial Burn Plan NODs for 1992 Trial Burn
and Certification
of Compliance Test.
-
Participated in strategy discussions responding to the Remanding
of
Tier III for BIF Hydrocarbons.
-
Liaison between a British cement manufacturer, waste fuel
provider and
on-site analytical lab to insure specification waste fuels for start-up
fuel burning program.
-
Provided recommendations for waste fuel analytical lab
modifications
to insure continued delivery of specification material.
-
Collaborated on ISO 9000 laboratory manual including QA/QC
documentation.
-
Produced Sales Training manual for European client.
-
Spent two weeks in England overseeing the start up of waste
fuels analytical
lab.
-
Primary author on paper published in 1993 A&WMA proceedings,
entitled
"Suitability of Hydrocarbon and Carbon Monoxide Measurement as
Combustion
Indicators in Cement Kilns".
-
Presented paper entitled "Suitability of Hydrocarbon and Carbon
Monoxide
Measurement as Combustion Indicators in Cement Kilns" at 1993 A&WMA
conference on Waste combustion in boilers and industrial furnaces.
-
Co-author on paper published in 1993 A&WMA proceedings,
entitled
"Metal Equilibration and Process Capture Efficiencies in Cement Kilns".
-
Co-author on paper published in 1993 A&WMA proceedings,
entitled
"Comparison of Metals Spiking Systems and Metals Compound Selection
Among
the Cement Kilns Conducting Compliance Tests".
-
Presented paper entitled "Typical Metal Concentrations in RCRA
Waste
Burned in Cement Kilns" at 1993 Incineration Conference.
-
Collaborated on response to Region V request for extensive
modification
of risk assessment data originally submitted with client 1992 BIF
Certification
of Compliance test report.
-
Coordinated and primary author of "A Metals Retention Study of
Pugmilled/Hydrated
Cement Kiln Dust" for a joint effort between 13 cement plants.
-
Coordinated and primary author of Trial Burn Plan and Quality
Assurance
Project Plan for waste fuel burning cement kiln Part B submission to
Region
VII.
-
Coordinated and primary author of RCRA Part B submittal for
waste fuel
burning cement kiln in Region VII.
-
Interacted with and provided written technical arguments for
industry
legal counsel in challenge to HC/CO BIF regulations.
-
Interacted with and provided written documentation and rationale
for
industry legal counsel(s) in response(s) to EPA enforcement actions.
-
Coordinated efforts and provided final collation of Initial
Facility
Report concerning client cement kiln dust disposal in State of
Illinois.
(1991)
-
Coordinated efforts and compiled Annual Facility Report
concerning client
cement kiln dust disposal in State of Illinois. (1992)
-
Participated in legal proceedings concerning requested variance
to CKD
regulations in Illinois.
-
Coordinated efforts and compiled Annual Facility Report
concerning client
cement kiln dust disposal in State of Illinois. (1993)
-
Reviewed EPA QA/QC data for 1992 cement kiln dust study and
provided
report highlighting problems with initial report to industry
organization
and EPA.
-
Performed comprehensive RCRA/BIF audit for waste fuel burning
cement
kiln in Region VII.
-
Coordinated BIF compliance sampling efforts of two cement kilns
in 1993.
-
Conducted site investigation and identified potential sources of
dust
organic contamination at waste fuel burning cement kiln.
-
Coordinated, produced and collated public relations program for
waste
fuel burning cement client.
-
Performed specific waste analysis for compatibility of
particular waste
with cement manufacturing process.
-
Conducted review and provided recommendations on application of
BIF
related Toxicity Characteristic Leachate Procedure (TCLP) methodology.
-
Conducted exhaustive research of organics to be included in CKD
organic
analysis according to BIF regulations.
-
Coordinated efforts to respond to Region V client information
request
which initially covered the first five months of 1993 and continues on
a monthly basis.
-
Participated in Region V regulatory audit as technical advisor
for client.
-
Managed the first fully integrated commercial hazardous waste
fuel blending
facility operating at a cement plant. In addition to comprehensive
management
responsibilities, including the management of a complete on-site
laboratory,
hiring and training was a major thrust to fuel expansion into other
states.
-
Authored a comprehensive laboratory and operations manual for a
hazardous
waste pilot plant in Paulding, Ohio. Variations of this manual were
subsequently
used for at least five additional facilities.
-
Developed a detailed Emergency Response Manual for use at RCRA
regulated
TSD facilities located at cement plants.
-
Coordinated cross-country inter-facility organic standard
exchange among
hazardous waste fuel laboratories which greatly expanded effective
compound
identification, a critical factor in protecting worker health and
safety.
-
Set up first hazardous waste fuel facility operating at a cement
plant
in the state of Alabama. This included laboratory set-up, initial
staffing
and operations management.
-
Co-authored RCRA Part B permit application for first hazardous
waste
fuel facility operating at a cement plant in the state of Indiana.
-
Personally identified equipment suppliers and specified
processing equipment
for an expansion into containerized waste handling and processing.
-
Directed and performed recruiting efforts for a waste management
company
expansion from approximately 50 employees in 1987 to over 200 employees
in 1991.
-
Successfully completed DuPont Crises Management Seminar, which
included
critique of videotaped interviews.
-
Developed first Crises Management document for national waste
processing
company. The primary purpose was for quick reference in a crisis
situation.
-
Performed waste oil market analysis for the Northwestern region
of the
United States.
-
Interfaced with state/province regulatory authorities in OH, NY,
AL,
IN, AZ, NV, IL, CA and Quebec.
-
Have been involved in community relations activity in OH, AL,
IN, NY
and MI.
-
Developed first RCRA training program designed for an integrated
waste
fuel/cement plant audience.
-
Managed and administered an eight facility RCRA training program
for
a national waste processing company.
-
Co-authored AA metals analysis in liquid organic waste fuels
paper.
-
Co-developed pioneer IC analytical techniques for use with
hazardous
waste fuel.
-
Set-up, operated, maintained and performed training for GC, AA,
IC &
Bomb Calorimeter instrumentation.
-
Completed self taught electronics course and subsequently traced
and
repaired electronic problem(s) down to board chips in laboratory
instrumentation.
-
Addressed and rectified an ongoing comprehensive acid, base, and
solvent
waste disposal problem from the generator side of the hazardous waste
equation.
-
Worked on permitting activities in AL, AZ, CA, IL, IN, OH, NY,
plus
Ontario and Quebec in Canada.
-
Functioned as informal "Corporate Plant Representative" in
matters of
waste fuel processing and safe practices.
-
Functioned as designated Safety Director for load acceptance in
the
Safety Director's absence.
-
Performed site incident investigations and interacted with
contractors.
-
Performed as lead person for public interaction including
presentation
in waste fuel facility siting efforts.
-
Served as international technical tour guide and host for French
parent
company operations representatives.
-
Performed extensive generator/customer and transporter
interaction through
load scheduling covering entire Midwestern United States and Canada.
-
Instrumental in developing five year internal strategy
emphasizing employee
participation in company development.
-
Have responded to personal training requests from cement plant
union
officials.
-
Eight years of interface between cement plant union and
non-union waste
fuel personnel.
-
Developed initial career path plan for waste fuel facility
employees.
-
Authored job descriptions for waste fuel facilities and
professional
corporate staff support personnel.
-
Authored Suitability of Hydrocarbon and Carbon Monoxide
Measurement
as Combustion Indicators in Cement Kilns.
-
Authored Metal Spiking Safety Considerations and Training.