You already have reams and stacks of test data. It is just as important to know how valid and defensible that data is.
Through years of experience, Gossman Consulting, Inc. has come to know that just because testing meets established QA/QC criteria does not automatically mean that that data necessarily represents true values. GCI is aware of test methods approved and required by government agencies which in fact give false values even when performed to the highest degree of accuracy and precision of the method. In some cases, this situation occurs because the regulatory agency has mistakenly applied methods to applications and matrices for which they were never truly validated.
GCI personnel have many years of study, training and experience with the practical application of data quality reviews, including providing expert witness testimony on testing and test data. Our personnel are experienced at taking valid test and operational data and performing mass balance calculations on process systems, thus supporting an understanding of the processes so that you can confidently undertake operational or environmental improvements.
This area of sound scientific understanding meeting practical application is where GCI can provide some of the most beneficial services. GCI has the background and experience to review routine QA/QC activities and the experience to ensure strong practical validations. You have important questions about test data: is it valid? does it meet the need? what can it tell us? GCI can provide your solutions to these questions.
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 exmission 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.
Prepared and made presentations at public meetings in Texas and Colorado regarding the use of HWF in cement kilns.
Provided expert witness testimony during legislative hearing in Texas regarding bills on hazardous waste management and facility permitting.
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.
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.
Provided detailed calculations of potential limits on metals in hazardous waste fuel based on proposed BIF regulations and stack dispersion models.
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.
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.
Co-developed the first quantitative model for evaluating relative health & safety risk from compounds found in HWF. This model has been copyrighted by Systech Corp. and continues to be utilized in evaluating potential hazardous wastes for inclusion in their hazardous waste fuel program.
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.
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.
Developed program for determining PCBs in HWF using computerized pattern recognition.
Coauthored Metal Equilibration and Process Capture Efficiencies in Cement Kilns.
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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