Review and Commenting
Gossman Consulting Inc. (GCI) performs
reviews and prepares comments on draft regulations and other
documents made available by the government for public comment. In
GCI has assisted our clients in preparing comments on draft hazardous
regulations, EPA guidance documents and various EPA studies including
- 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
- 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.
- Reviewed and provided comments on
Subpart CC regulations on air emissions controls
- Editor of Cement and Waste Materials
Conversion News, a monthly newsletter.
- Primary reviewer and author of a set
of comments on the EPA Dioxin Reassessment.
- Reviewer and primary author of a set
of comments on the EPA Combustion Emissions Technical Resource Document
- Participated in strategy discussions
responding to the Remanding of Tier III for BIF Hydrocarbons.
- Interacted with and provided written
technical arguments for industry legal counsel in challenge to HC/CO
GCI has prepared a number of papers commenting on EPA draft
Although portions of these comments may have been prepared on behalf of
client, the comments presented in these papers are GCI's. In many cases
tone reflects GCI's unique position outside of industry thus allowing
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
that represent the client's position with a tone representative of the
of our client's.
in Kilns in the United Kingdom A
Comparison of Regulations in the United Kingdom versus the United
Variances in the Interpretation
and Implementation of the BIF Regulations"
Risk to Health, Safety and the
Environment Due to the BIF Regulation"
Notes "Hazardous Waste Combustor
Review - Chapter 1 Applicability of the HWC Regulation to Cement Kilns”
Notes "Comments on Draft SW-846",
GCI Tech Notes
"Subpart CC Voc Emission
GCI Tech Notes
"Dioxin Health Assessment
Review and Comment, (EPA/600/BP-92/001a,b & c)”, March-95
GCI Tech Notes
"EPA Dioxin Exposure Assessment
"Municipal Waste Combustion and
"Review of EPA’s Sham Recycling
"Review of Guidance on Trial Burns”,
"Comments on the New EPA Waste
Plan Guidance Manual”, July-94
"Review of EPA-454/R-93-032
National Air Pollutant Emission Trends”, April-94
HWF Notes "CKD
Report to Congress Comments”,
"Review of EPA Draft
of Exposure Assessment Guidance for RCRA Hazardous Waste Combustion
HWF Notes "The
EPA Proposed Hazardous Waste
Identification Rule (Potential Impact on Cement Kiln Dust)”, July-92
Regulations Summary For Compliance