QA/QC Program Development

Gossman Consulting, Inc.

SOLUTIONS

QA/QC Program Development

Service Description

Gossman Consulting, Inc. provides solutions to your difficulties with data quality assurance and quality control. GCI staff members have conducted many facility audits specifically to determine problems associated with QA/QC concerns. A technical and experienced staff can review your existing QA/QC programs to solve known problems or determine unknown deficiencies and provide remedies. An operation plan should contain standard operating procedures which define the specific steps that should be taken to ensure quality results. Your plans may cover many operational activities such as certain analytical steps to document product quality or to calibrate environmental control equipment. Whatever the purpose, they should be supported by strong QA/QC. The GCI staff can also develop a QA/QC program from scratch to meet the needs that the specific situation requires. GCI staff members have experience developing many operation plans both while they were in operations and when they have consulted with other companies.

GCI has the proven experience to solve all types of QA/QC data problems with such programs as, environmental field sampling and analysis, analytical laboratory sample preparation, analysis and reporting, process data reporting, stack testing and reporting, CEM operations and testing, new regulation evaluations, and litigation or expert witness testimony. The experience is proven based on the many successful and approved operations plans, that include QA/QC, currently in use that GCI personnel have developed, implemented or contributed oversight to. The experience is also proven by a large number of successful regulatory reviews and expert witness testimonies that GCI has provided to clients and that included QA/QC evaluations.

Experience

David Gossman

Acted as QA/QC manager for one of the first comprehensive RCRA Trial Burns at a cement plant.
Performed a comprehensive review of a proposed update to SW-846.
Performed a detailed QA/QC review of mercury emission data used by EPA to develop/justify MACT controls on cement kilns.
Performed a detailed QA/QC review of dioxin emission data from cement plants not utilizing hazardous waste fuels.
Acted as QA/QC manager for 1995 update ROC tests at multiple cement plants.
Reviewed the EPA draft Combustion Emissions Technical Resource Document (CETRED) and assisted various clients in providing technical comments and corrections to EPA.
Performed a detailed QA/QC review of dioxin emission data compromising over 20 tests at a single cement plant, both under baseline conditions and while burning hazardous waste.
Assisted in the review and preparation of client comments on the EPA draft Dioxin Assessment. Assisted international clients in dealing with erroneous EPA conclusions found in the draft report in order to prevent the erroneous conclusions from negatively impacting local permitting decisions.
Prepared a new Waste Analysis Plan and QA/QC Plan for a cement plant using both liquid and solid hazardous waste fuel.
Prepared an analysis of existing metal emission data from cement kilns and incinerators burning hazardous waste, and recommended technology based metal emission standards which have been presented in a petition for rule making to the USEPA by the Cement Kiln Recycling Coalition.
Assisted in performing a critical review of QA/QC data from an EPA study of cement kiln dust.
Assisted in the development of a "green grass" waste fuel burning facility in the United Kingdom with special emphasis on appropriate quality control measures, process monitoring permitting and stack testing.
Developed a detailed GC-MSD technique for determining volatile and semivolatile organics in hazardous waste fuel. The technique is now being used in at least three hazardous waste fuels laboratories.
Provided technical support on various issues in support of the cement industry's lawsuit against EPA regarding certain aspects of the BIF regulations.
Assisted in the development of hazardous waste fuel specifications and laboratory testing methods for a cement kiln using hazardous waste fuel in Australia.
Performed comprehensive audits of contractor operated laboratories testing hazardous waste fuel at three cement plants.
Assisted in the preparation of an ISO 9000 (British Standard 5750) certification application for a hazardous waste fuel laboratory in the United Kingdom.
Managed and wrote the reports for BIF compliance tests/trial burns at four cement plants.
Developed and wrote a screening method for radioactive material contamination of HWF.
Developed laboratory testing methods to screen HWF for selected pesticides.
Managed and wrote the reports for BIF compliance tests/trial burns at four cement plants.
Developed sample preparation methods for homogenizing non-homogeneous samples of liquid and solid HWF prior to analysis.
Developed and wrote a comprehensive laboratory operations manual for use at multiple HWF testing laboratories.
Designed and set up a new laboratory for HWF testing in Ohio. Subsequently trained the new lab manager to operate and maintain the lab in accordance with EPA guidelines.
Developed laboratory operating procedure that allows for the determination of sub-ppm levels of mercury in HWF in less than two hours using EPA SW-846 methodology.
Designed and set up a new laboratory for HWF testing in Tennessee. This is the first HWF laboratory designed specifically to comprehensively test solid HWF prior to acceptance and is the first to use x-ray fluorescence spectroscopy to determine metals.
In conjunction with Southdown Corp., performed a study to determine the viability of proposed EPA stack testing methodology for HCl emissions. Results indicate that ammonium chloride and other chloride salts produce false positives using the methodology.
Performed comprehensive laboratory based study, including field sampling, of cement kiln dust and cement clinker stored and generated at cement plants throughout the country.
Developed and managed the implementation of stack testing plans for cement manufacturers using or planning on the use of hazardous waste fuel. Tests were performed to satisfy state air permit authorities as well as provide data to be used for future EPA requirements.
Performed RCRA and CAA audits of existing cement kilns utilizing HWF.
Provided detailed calculations of potential limits on metals in hazardous waste fuel based on proposed BIF regulations and stack dispersion models.
Wrote a complete set of RCRA operating plans for a RCRA interim status hazardous waste fuel storage facility located at a cement plant.
Performed the first comprehensive, published study on the fate of trace metals in the cement manufacturing process. The study provided special insight on how recirculating loads, as well as the point of introduction, can effect the fate of metals in cement kilns.
Authored a series of published reviews of proposed EPA Boiler and Industrial Furnace regulations. These reviews included specific technical analysis of potential impacts on cement kiln waste fuel operations with suggestions and guidance for providing comments to EPA.
Developed an additional HWF facility for Safety-Kleen at a cement plant in South Carolina. This facility has the largest storage facility capacity of any in the country.
Developed and managed a "green grass" HWF facility at the largest cement kiln in the world. This process included permitting, community relations, facility design, construction, personnel hiring, training and management, contract negotiations with the cement manufacturer and training of marketing and sales personnel. The facility was on line burning HWF within five months after a decision was made by both companies to pursue the project. This HWF facility permitted McKesson Envirosystems revenue and profitability growth to record levels and was one of the key reasons for Safety-Kleen's acquisition of McKesson Envirosystems.
Assisted in the development of McKesson Envirosystems standard analytical procedures, QA/QC program and health & safety evaluation system.
Performed a comprehensive systems analysis at three McKesson Envirosystems solvent recycling/waste fuel blending facilities to improve efficiency and QA/QC. Negotiated corporate purchase of laboratory equipment and computers worth $250,000 to standardize plant labs.
Assisted in the technical development and marketing of a cement kiln waste fuels outlet in Puerto Rico, the first and only in the Caribbean. Developed and helped to equip a laboratory for HWF testing in Puerto Rico and trained laboratory personnel.
Supervised the technical, regulatory and safety aspects of test burns in cement kilns in Illinois, Pennsylvania, California, Kansas, Ohio, and Ontario, Canada from 1982 to 1985.
Designed and set up new laboratories for HWF facilities in California and Kansas. Trained chemists and managers for both facilities.
Managed the corporate safety and regulatory compliance program for Systech Corp. This program included review of all pre-shipment analysis for Systech for over five years. This review process included a comprehensive toxicological review of each compound identified in every waste stream.
Developed the first comprehensive HWF specification which met the needs of product (cement) quality, environmental protection and personal health & safety in 1980.
Developed the first comprehensive and field tested system for determining the chlorine specification for HWF used in cement kilns. This system remains proprietary to David Gossman. The system takes into account a wide variety of parameters including raw material and current fuel chemistry as well as kiln system design.
Developed the first analytical methodology for identifying volatile and semi-volatile compounds with potential health & safety impacts in HWF. Later enhanced this methodology by utilizing wide bore capillary chromatography and multiple detector systems.
Developed the first three tiered hazardous waste testing program in 1981 including pre-shipment testing, shipment receipt testing and blended waste testing. By using such a multi-tiered system, this program was the first to effectively deal with the QA/QC issue relative to testing at RCRA facilities.
Developed and published the first high speed methodology for determining metals in HWF utilizing organic matrix dilution and direct aspiration into an atomic absorption spectrophotometer.
Developed and published the first analytical methodology to utilize ion chromatography to determine F, Cl, Br, S, and P in HWF.
Developed and published the first analytical methodology specifically designed to determine PCBs in HWF. The method was eventually expanded to utilize computerized, graphics based pattern recognition.
Managed the first commercial hazardous waste fuel (HWF) blending facility operating at a cement plant. The facility in Paulding, Ohio was the first of its kind with a complete on-site laboratory and storage facility operating in full compliance with RCRA in 1980.
Current QA/QC Manager for regional commercial lab performing soil and water testing, ChemRight Laboratories, Inc.

Sue Gossman

Designed and implemented internal quality control management.
Designed and implementing nation wide BIF test database.
Supplied compliance test data analysis support including mass balance analysis, CEM analysis, AWFCO and other limit calculations as well as preparation of POC and COC forms.
Designed and programmed emission database with custom user interface.
Provides feed rate and CEM data reduction for preparing monthly synopses and reports to regulatory agencies for facilities burning hazardous waste as fuel.
Performed spreadsheet analysis of metals emissions from cement kilns and commercial incinerators burning hazardous waste.
Calculated and provided BIF compliance assistance for five facilities including precompliance certification calculations and preparation, BIF Trial Burn data compilation and reduction, and supporting data processing for regulatory reporting and compliance.
Designed and implemented internal customized databases.
Provides high volume data reduction using OCR and data conversion technologies.
Designed and implemented micro computer system for quality control selection via randomized sampling for acceptance of drum containerized hazardous waste in an MS-DOS application.
Provided user support, systems programming and hardware integration for a prototype Just In Time automobile parts assembly line on IBM PC Network System. Included error correction of existing networked system as well as new system functions. New programming included interface with message sign boards and bar code label printing and reading. Other support entailed hardware maintenance, trouble-shooting and repair.
Provided user support and systems programming using RPG on IBM System 34 for parts inventory processing and accounting for a materials handling retailer.
Provided systems analysis and design for a CPM microcomputer and hard disk network system using Turbo PASCAL and assembler programming for a cemetery. System included broad based data entry and verification of extended data bases. Specialized programming provided rapid file access to large data bases (one data base over 60,000 records) on the primitive technology available in the early 80's.
Transferred and translated CPM cemetery programs and data to PC based MS-DOS compatible network. Retained or improved essential form and function of all aspects of system in transfer from CPM to MS-DOS operating system. System support provided through telephone based master-slave linkage of developmental and user site systems.
Performed multi-plant systems analysis of hazardous waste fuel receipt and handling for a major waste fuel recycler, encompassing material receipt, regulatory record-keeping, accounting and contractual needs.
Designed and implemented multi-plant microcomputer system for receipt of hazardous waste fuel, using Turbo PASCAL, assembler and BASIC programming. System provided real-time receipt, processing, accounting support and invoicing of suppliers as well as early modem transmittal of recorded information to the corporate site.
Developed program for determining PCBs in HWF using computerized pattern recognition.
Provided user support with emphasis on statistical software (SPSS-a major mainframe statistical package and STAT-a statistical package developed and maintained on-site) on CDC 750 and CDC 6500 mainframe computers.
Provided software development, installation and maintenance with emphasis on hardware interfaces for CDC 750 and 6500 mainframe computers. Provided generalized debugging of the operating system and high-level programs such as compilers and editors. Modified system booting algorithms to utilize 9 track instead of 7 track tapes. Maintained hard disk systems in an environment which required manual recording of hard disk flaws. Taught systems class to potential new employees.
Coauthored Metal Equilibration and Process Capture Efficiencies in Cement Kilns.
Current Operations Manager for commercial soil and water testing laboratory, ChemRight Laboratories, Inc.

Existing SOLUTIONS

GCI has prepared a number of papers relevant to quality assurance and quality control. (If a link to a paper title is not yet available please e-mail with your fax number for a copy.)

"Comparison of Metal Emissions from Cement Kilns Utilizing Hazardous Waste Fuels with Commercial Waste Incinerators"

"Metal Equilibration and Process Capture Efficiencies in Cement Kilns"

"The Use of Monochlorobenzene as a Principal Organic Hazardous Constituent for Destruction Efficiency Determinations in Cement Kilns"

"Quality Control of Hazardous Waste Fuel"

"Suitability of Hydrocarbon and Carbon Monoxide Measurement as Combustion Indicators in Cement Kilns"

"Typical Metal Concentrations in RCRA Waste Burned in Cement Kilns"

"The Fate of Trace Metals In The Wet Process Cement Kiln"

"Cement Kilns Sources of Chlorides Not HCl Emissions"

"Comparison of Metals Spiking Systems and Metal Compound Selection Among the Cement Kilns Conducting Compliance Tests"

"2,3,7,8-TCDD Equivalent Emissions from Cement Kilns Burning Hazardous Waste"

"A Method for the Rapid Semi-Quantitative Identification of Hazardous Organic Constituents in Liquid Organic Hazardous Waste Streams"

"A Review of the Usefulness of Various ASTM and SW-846 Methods Which May Be Used by the Thermal Treatment Industry"