Regulatory Review and Commenting

Service Description

Gossman Consulting Inc. (GCI) performs extensive reviews and prepares comments on draft regulations and other technical/policy documents made available by the government for public comment. In recent years GCI has assisted our clients in preparing comments on draft hazardous waste regulations, EPA guidance documents and various EPA studies including those on dioxins.

Experience

David Gossman

• Performed a comprehensive review of a proposed update to SW-846.
• Reviewed the EPA draft Combustion Emissions Technical Resource Document (CETRED) and assisted various clients in providing technical comments and corrections to EPA.
• 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.
• Assisted in the development of a petition for rule making submitted to EPA by the Cement Kiln Recycling Coalition.
• Provided technical support on various issues in support of the cement industry's lawsuit against EPA regarding certain aspects of the BIF regulations.
• Provided expert witness testimony during legislative hearing in Texas regarding bills on hazardous waste management and facility permitting.
• Performed studies of the impact of the proposed Boiler and Industrial Furnace regulations and other regulations on the hazardous waste/cement kiln market.
• Provided detailed calculations of potential limits on metals in hazardous waste fuel based on proposed BIF regulations and stack dispersion models.
• 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.
• Prepared a management summary of the BIF regulations as they apply to cement kilns burning hazardous waste.

Qualification Statements

David Gossman, and Susan Gossman

Relevant Publications

GCI has prepared a number of papers commenting on EPA draft regulations. Although portions of these comments may have been prepared on behalf of a client, the comments presented in these papers are GCI's. In many cases the tone reflects GCI's unique position outside of industry thus allowing us to make statements or present materials that might not be appropriate as part of a comment coming from industry. GCI prepares comments on behalf of our clients that represent the client's position with a tone representative of the desires of our client's.

• Burning Waste in Kilns in the United Kingdom A Comparison of Regulations in the United Kingdom versus the United States EPA Regulations
• EPA Regional Variances in the Interpretation and Implementation of the BIF Regulations
• The Added Risk to Health, Safety and the Environment Due to the BIF Regulation
• GCI Tech Notes "Hazardous Waste Combustor Review - Chapter 1 Applicability of the HWC Regulation to Cement Kilns” Oct-96
• GCI Tech Notes "Comments on Draft SW-846", Jan-96
• GCI Tech Notes "Subpart CC Voc Emission Controls”, Oct-95
• GCI Tech Notes "Dioxin Health Assessment Document Review and Comment, (EPA/600/BP-92/001a,b & c)”, March-95
• GCI Tech Notes "EPA Dioxin Exposure Assessment Comments”, Feb-95
• HWF Notes "Municipal Waste Combustion and MACT”, Dec-94
• HWF Notes "Review of EPA’s Sham Recycling “Policy”, Nov-94
• HWF Notes "Review of Guidance on Trial Burns”, Aug-94
• HWF Notes "Comments on the New EPA Waste Analysis Plan Guidance Manual”, July-94
• HWF Notes "Review of EPA-454/R-93-032 Entitled National Air Pollutant Emission Trends”, April-94
• HWF Notes "CKD Report to Congress Comments”, Feb-94
• HWF Notes "Review of EPA Draft 'Implementation of Exposure Assessment Guidance for RCRA Hazardous Waste Combustion Facilities'", Nov-93
• HWF Notes "The EPA Proposed Hazardous Waste Identification Rule (Potential Impact on Cement Kiln Dust)”, July-92

If you have questions or wish to set up a meeting please contact David Gossman at (563) 652-2822 or via e-mail.

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