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Gossman Consulting, Inc

Thermal Treatment Facility Trial Burns and Compliance Tests

Service Description

Gossman Consulting Inc. has been compliance test since 1991. In many cases they have managed those tests as primary contractor. GCI personnel have not only been involved in test/trial burns in the United States but in a number of foreign countries as well. GCI was particularly active during all of the BIF compliance testing efforts in 1991 & 1992. While this is not an uncommon claim by many in the industry today, GCI was primary contractor for four out of 20 some BIF tests conducted in 1992 and was involved in 3 other BIF tests that Summer, accounting for well over 25% of the BIF testing performed that Summer. GCI has also written and conducted numerous certification of compliance testing and recertification of compliance testing since 1992. GCI conducted all of the compliance tests, on which we were primary contractor, as if these compliance tests were in fact trial burns. This was designed to take advantage of the "data-in-lieu-of" portions of the BIF regulations. Since that time, GCI has written three trial burn plans and conducted two official trial burns, one of which was conducted in two stages. GCI has also been involved in two other trial burns.

Experience

Gossman Consulting, Inc. has developed compliance test/trial burn protocol and asssisted with the conducting of tests for hazardous waste fuel operations at the following locations:

GCI personnel have also been involved in performing compliance tests at these additional locations:

GCI also provided the QA/QC program for the compliance test/trial burn protocol for the following facilities:

It is significant to note that much of the compliance test data that has been produced/collected in the United States since the advent of the BIF rule has been heavily scrutinized by several organizations including the USEPA. While much data has either been excluded or labeled with restrictive conditions, data from GCI testing has passed with flying colors. This is largely because of the riqorous QA/QC program implemented by GCI.

Existing SOLUTIONS

In addition to the test reports that are available for public review, GCI has prepared a number of papers related to trial burns and compliance testing. Most of those papers and/or articles are available in the GCI Internet Library. A partial list with readily accessible internet links are as follows:

"Continental Cement Trial Burn Strategy"

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

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

"Burning Waste in Kilns in the United Kingdom A Comparison of Regulations in the United Kingdom versus the United States EPA Regulations"

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

"EPA Regional Variances in the Interpretation and Implementation of the BIF Regulations"

GCI Tech Notes "A Caution in the Use of Analytical Data in Calculating TEQ Values for Dioxin Reporting”, Dec-95

"Continental Cement Trial Burn Strategy Follow-up"

GCI Tech Notes "Appropriate Sampling Frequency for Cement Process Samples During Stack Testing”, July-95