Professional Qualifications – David Constans



David Constans received a B.S. Chemical Engineering from the University of North Dakota in 1970. He has held numerous positions in chemical process design and production.  


Specific experience includes the following:

·Assisted in providing expert witness testimony and litigation assistance in relation to litigation involving accidents at hazardous waste management facilities.

·Assisted in providing an expert witness report on the cause of an explosion in the vapor hood space at a hazardous waste fuel storage facility in a cement plant.            

·Managed HWC MACT compliance testing programs

·Managed PC MACT compliance testing programs.

·Assisted in performing a company wide environmental compliance audit including management strategies for more effective compliance.

· Numerous articles written for Gossman Consulting, Inc. Tech Notes on a range of technical subjects, many of these based on issues that confront our clients:

-    Liquid Hazardous Waste Handling Systems, Pump Basics

-    Tire Derived Fuel Uses in Cement Kilns, Co-authored with D. Gossman

-    Liquid Alternate Fuel Combustion Burner Design

-    Hazardous Waste Fuel/Solvent Recycling Gaskets and Seals

-    Turbulent Flow in Pipes

-    Liquid Hazardous Waste Particulate Size Reduction

-    Risk Assessments and Process Upsets

-    Vapor Balance System Control Efficiency

-    6-Minute Block Associated with Opacity Requirements

-    Catastrophic Accidents-Caused by Multiple Failures of Elements Within a Safety Management System

-    Comments on Writing on Operations and Maintenance Plan

-    Primary Aluminum Production Wastes, Spent Potliner, K088

-    HWC MACT Changes by Court Ruling

-    MACT Testing-Do You Measure Up? Co-authored with David Gossman

-    Commentary on Dioxin and PCB Contamination of Food in Europe

·In 2002 completed a comparison of EU and US Environmental Regulations for an Asian client.

·Part of a team that provided technical assistance during litigation.  Resulting in a favorable settlement for our client.

·Wrote and presented papers at various American Waste Management Association Conferences.  Some of these were co-authored with other GCI consultants or clients.  Each covered a subject that was topical at the time it was presented, usually an examination of current regulations and their implementation:

-    Continental Cement Trial Burn Strategy

-    Burning Waste in Kilns in the United Kingdom-A Comparison of the Regulations

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

-    Development and Design of Hazardous Waste Fuel Blending Facilities in Developing Countries

-    Preparation of a CMS Plan as Part of HWC MACT

-    The Differences in Implementation between the HWC MACT Regulation and the PC MACT Regulation

·Numerous facility inspections and regulatory compliance reviews of facilities.  Many of these are conducted via the client’s legal council.  Others conducted prior to purchase of the facility.

· Wrote and executed Dioxin Emission Test Plan at a major cement manufacturer facility in Chile, S.A.

· Supervised development of and edited an Operations and Maintenance Plan (O & M Plan) for a major U.S. cement manufacturer.  This plan is now being used as a template for all of their facilities.

· Co-authored an HWC MACT ICPT plan for a major U.S. cement company.

· Authored two Continuous Monitoring Systems (CMS) certification documents.  These CMS Certifications are a required part of the HWC MACT requirements.

· Provided consulting services to a major U.S. aluminum manufacturer and successfully completed a trial utilizing spent potliner as fuel in a cement kiln.

· Continue to provide quality POHC and metals spiking services for ROCs and Trial Burns.

· Member of a team assembled to remediate a closed cement manufacturing facility on Vancouver Island.

· Designed facility modifications including a liquid alternate fuel burner design for a major Canadian cement company.

· Presented a co-authored paper at the April 1997 AWMA BIF conference AObservations and Comments on EPA/DDE Mercury CEMs Demonstration at Holcim's Holly Hill Facility.

· Presented and co-authored a paper at the April 1998 AWMA BIF conference entitled: ABIF Testing - Is There Anything Else to Learn?

· Co-authored and presented a paper at the September 1999 AWMA BIF conference on ADevelopment and Design of Hazardous Waste Fuel Blending Facilities in Developing Countries.

· Authored a HAP test plan QAPP and successfully executed the plan at a Colorado cement location.  This included the use of the new FTIR on-line analyzer.

· Co-authored three Trial Burn plans and QAPPs for cement kilns in Indiana and Missouri.  Spiked metals and POHCs for these tests.

· Authored a GCI Tech Notes, Should You Test for HAP Emissions? September 1996.

· Authored a paper presented at an International Incineration Conference in May 1996, Sources of PCDDs/PCDFs in Cement Kiln Emissions.

· Co-authored a paper presented at the A&WMA BIF Specialty Conference, Continental Cement Trial Burn Strategy.

· Co-authored a paper presented at the A&WMA BIF Specialty Conference, Continental Cement Trial Burn Strategy Follow-up.

· Authored the February 1997, GCI Tech Notes, Determining Organic Compound Destruction Efficiency.

· Authored a Used Oil Trial Burn Plan for a New Zealand cement company and oversaw its completion.

· Authored a Trial Burn Plan for a kiln in the United Kingdom to burn a non-hazardous waste.  Designed the facility to supply the waste to the kiln for the test burn.  Trial Burn Test was successfully executed by the cement company.

· Provided process design and equipment specification for a hazardous waste treatment and fuel blending facility in Chilé.

·Provided consultation to a cement company in Chilé on the potential use of waste fuel in their cement kiln.

· Authored GCI Tech Notes August 1995 “Organic Vapor Control, EPA's Subpart CC Regulations”.

·Authored GCI Tech Notes, Ambient S02 5-Minute Peak Rule, January 1995.

·Co-authored HWF Notes, Clean Air Act Hazardous Air Pollution List, October 1994.

·Authored HWF Notes, Review of Guidance on Trial Burn, August 1994.

·Authored HWF Notes, Submittal of Data-in-Lieu of Trial Burn, June 1994.

·Authored Burning Waste in Kilns in the United Kingdom, a paper presented at the 1993 A&WMA-BIF Conference.

·Designed a pilot waste fuel supply system for a kiln in Northern Ireland.

· Designed a pilot waste fuel supply system and Trial Burn Plan for a kiln in the United Kingdom.

·Wrote extensive training and emergency response manuals.

·Trained the operators and supervised successful startup.

· Co-authored a Trial Burn Plan and RCRA Part B Application for a kiln in Missouri.

·Authored a Revised Certificate Of Compliance Trial Burn Plan for a major cement company in Indiana.  Oversaw the execution of the trial burn, wrote and submitted the trial burn report.

·Provided consultation and facility process design to a potential waste fuels supplier in Venezuela.

·Provided an international waste management company with a technical evaluation of several hazardous waste and solvent recovery facilities in Australia and New Zealand prior to acquisition negotiations.

· Organized and managed the writing of a waste fuels laboratory procedures manual to meet the ISO‑9002 standards.

· Co-authored and presented a paper at the AWMA‑BIF Conference in March 1993 on the comparison of the various metals spiking alternatives used in the compliance tests.

· Conducted Industrial Furnace BIF related training.

· Conducted and/or collaborated on five Post‑Compliance Certification BIF Audits.

· Actively involved with approximately one‑third of the BIF Certification of Compliance tests conducted in 1992.

·Performed BIF Metals spiking for seven different Certification of Compliance tests including metals selection and purchase arrangements, metals solution strength calculation and blending, equipment design and setup, operation and documentation during the tests and proper RCRA disposal of residual chemicals and wastes.

· Co-authored five Compliance/Trial Burn Plans.

· Co‑founder of an environmental service company specializing in the RCRA and BIF operations and compliance requirements of cement kilns utilizing hazardous waste fuels.

·As Director of Resource Recovery Operations for a major cement company.

-   Co-authored Part B applications for kiln fuels receiving and storage facilities for four cement plants.  This included the management of the engineering design contractor and personnel training as well as the writing of the engineering and operations sections of the application.

-    Co-authored performance test plans (similar to that required later by the BIF regulations) for three kilns that included the injection of metals solutions and POHCs.

-    Designed, installed and operated these injection systems during the subsequent tests.

-    Assisted in the design, installation and initial operation of a hazardous waste fuel laboratory located at a cement plant.

-    Designed, installed and operated a solvent recovery distillation and storage facility and a cement kiln fuels blending facility.

-    Completely redesigned the deepwell injection system, installing new pumps, piping and storage for this facility.

-    Co-authored a Part B application.  Received Part B permit for this facility.

-    By the end of six years, the staff had grown from 20 to 120 people and was producing over one million gallons per month of kiln fuel, processing approximately 100,000 gallons per month of recoverable solvent and disposing of approximately 700,000 gallons per month of aqueous hazardous waste through deepwell injection.

·Superintendent of a 30-year-old Sodium Sulfate/Hydrochloric Acid facility.  Controlled production costs, improved product quality, saving the company over $800,000 in two years.

·Chief Process Engineer for an early waste solvent recovery facility at a time when RCRA had not been promulgated and a State permit to operate was required.

-    Designed, installed and operated waste solvent distillation and storage facilities.

-    Wrote and submitted an engineering description and operations manual.

·Shift Foreman, Production Foreman, then Superintendent over all of the Organic Production Operations (primarily chlorinated hydrocarbons) for the Wichita, KS facility of Vulcan Materials Company, Chemical Division.  Responsible for setting production and safety records.

·Process/Production Engineer for the construction of a grass roots chlorinated hydrocarbon facility.  Responsible for the commissioning of the facility, writing the training manual and training the operators.  Successfully conducted the performance test of the facility at 115% of design capacity.

·Managed a water pollution control laboratory.

·Performed laboratory and pilot plant studies, using this data to design a water pollution control system for a major fiberboard manufacturer.

·Authored the operations and engineering design portions of the NPDES permit applications for the system described above.

·Designed, installed and operated pilot plant production equipment for a major adhesives manufacturer.  Took three products into full production, including training operators and laboratory technicians.

·Authored Comparisons of Metal Spiking Systems and Metals Compound Selection among the Cement Kilns Conducting Compliance Tests.

·Co-authored Metal Equilibration and Process Capture Efficiencies in Cement Kilns.

·Co-authored Suitability of Hydrocarbon and Carbon Monoxide Measurement as Combustion Indicators in Cement Kilns.

·Authored HWF Notes, The BIF Audit, November 1992.

·Co-authored Commercial BIF Compliance Test Results‑1992. Copyright 1993.