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.
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.
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.
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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