ARNOLD LEWIS FELDMAN

Education: B.S.Ch.E.

New Mexico State University

January 1969

A.A.

Staten Island Community College

January 1966

Experience:

January 2000JJDS Environmental

To PresentOwner/Principal

Developed and implemented site-specific Hazardous Waste Combustor Training and Certification program. Assisted in developing Alternate Analytical Method petition. Aided client in reporting requirements for new Incinerator MACT standards. Reviewed Trial Burn and Performance Test plan for RCRA Incinerator. Support for development and submittal of various RCRA plans and documents in compliance with a Consent Decree. Supported law firms: on waste classification and sampling issues related to characteristic waste classification; alternates to product recycling; and off-site disposal options. Supported development of RCRA Interim Status plans and Part B permit application for new Land Disposal facility including RCRA Combustor; also acted as budget/cost control manager for regulatory and analytical portions of propject. Performed compliance audits on various hazardous waste treatment/disposal facilities. ViceChair ASME Committee on Hazardous Waste Incinerator Operator Certification Committee and Chair Testing Subcommittee.

October 1991 FMC Corporation

to January 2000 Manager Regulatory Compliance, Solid Waste

May 1995 to Present

Corporate oversight reponsibility for solid and hazardous waste. General responsibilities

include keeping Corporate and plant staffs informed of new and pending regulations and steps involved in complying with them. Responsible for interpreting RCRA regulations, preambles, guidance, policy statements and court decisions for FMC facilities in U.S. Responsible for interpretation of OECD and Basel waste protocols. Conducted internal environmental audits on various domestic and international facilities. Conducted environmental audits on off-site commercial facilities. Prepared various compliance and training manuals including “Understanding RCRA”, “Understanding California RCRA”, “Agency Interaction”, “Paperwork and Inspections”, “RCRA Inspections”, “RCRA for Project Managers”and “LDR Compliance”. Conducted various RCRA training programs. Prepared comments on various proposed federal regulations including Carbamate listing and Phase III and IV LDR rules. Led FMC litigation on Carbamate Listing rule resulting in significant modifications from final rule. Developed RCRA plans for newly regulated(carbamates) facilities(4); led implemetation teams for facilities including conducting all initial training. Project Manager for development of major Part B permit application(34 - 4” volumes); responsible for negotiaiting permit. Responsible for developing and implementing compliance programs for 90 day areas, interim status plans, and eventually Part B permit for this facility. Led FMC team in negotiating national waste disposal contracts. Developed new waste tracking program for FMC worldwide that significantly reduced paperwork. Member CMA RCRA Task Group. Member CMA Definition of Solid Waste, Technology and Subtitle D Work Groups.

Senior Environmental Engineer

October 1991 to May 1995

Corporate oversight responsibility for two

divisions consisting of ten plants and one

additional facility. Included were two of

FMC's largest plants; an industrial chemical

plant and military vehicle manufacturing

plant. Industrial chemical plant is a

CERCLA site currently conducting RIFS.

Military vehicle facility included nine

remedial sites ranging in scope from pre-

RFI(workplan development) to post ROD

activities, property sale and lease termination. Negotiated various permits, Consent Orders and remediation plans with state/federal agencies. Project Manager for new site acquisition and property development (Phase I and II). Project Manager for FS for closed chemical plant. Prepared project scopes and bid packages for multiple investigations. Conducted internal environmental audits on various domestic and international facilities. Conducted environmental audits on off-site commercial facilities. Member CMA Responsible Care Pollution Prevention Code Implementation Work Group. Member CMA Definition of Solid Waste Task Group. Member AMC "Derived-from"/Mixture Rule Litigation Group. Conducted RCRA training

and audits at various FMC plants. Prepared comments on various proposed federal regulations.

May 1976 Olin Corporation

to October 1991 Environmental Affairs Associate

July 1984 to October 1991

Overall environmental responsibility for

major chemical plants. Prepared and negotiated NPDES and Part B permits for muliple plants/units. Prepared additional Part B permit applications. Prepared closures in lieu of RCRA applications. Developed and implemented closures of multiple RCRA units. Developed and implemented Superfund Remedial Investigation. Reviewed, summarized and pre pared comments on Federal/State regulations. Responsible for Land Disposal Ban compliance. Responsible for Olin Chemicals Waste Management program. Developed Olin Chemicals Waste Minimization program. Chemicals Group Waste Minimization Program Manager. Member CMA Pollution Prevention Industry Programs Work Group. Member CMA RCRA Survey Work Group. Coauthor CMA Waste Minimization Resource Manual. Coauthor CMA Pollution Prevention Manual. Member NGA/USEPA RCRA Bienniel Report Task Force. Responsible for environmental compliance of Olin used warehouses/terminals and distribution system.

Manager Environmental Affairs-Joliet Plant

December 1980 to June 1984

Manage all phases of the Environmental Affairs Department at the Joliet Plant. Assure that the plant was in compliance with all Environmental laws. Interfaced with governmental agencies on all matters related to the environment. Prepared and submitted reports. Initiated and managed Site Specific Rule Change to allow burning high sulfur coal.

Developed plant waste dispoal plan and PCB

policy. Began NPDES repermitting. Resumed

energy responsibilities (as stated below) in

January 1983 in addition to environmental.

Energy Coordinator

March 1977 to December 1980

Manage all phases of energy including conservation, usage, supply and compliance with

State and Federal regulations at the Joliet

Plant. Developed and prepared budget

(approximately $14MM). Initiated and co-

ordinated capital projects. Prepared governmental reports. Represented the plant in various court rate cases. Oversaw maximization of boiler efficiencies including fuel selection; facility had 3 coal and 2 gas/oil boilers. Prepared feasibility study and was plant representative on Sulfuric Acid Plant project.

Senior Production Engineer

May 1976 to March 1977

Developed and evaluated capital projects at the Joliet Plant. Implementated improvements at the plant including process upgrading.

Projects included: heat and dust recoveries; debottlenecking of phosphate process; installation of condensate return systems.

February 1974 Universal Oil Products

to May 1976 Process Engineer

Reviewed daily operations of catalyst production

plants and utility facilities. Helped

commercialize new catalyst type. Computerized

accounting and operating parameters for catalyst

plants. Various process design and

improvement projects.

October 1972 to E.I. DuPont/Newport Army Ammunition Plant

January 1974 Process Engineer

August 1973 to January 1974

Engineering responsibility for nitration in TNT manufacture. Typical duties included review of daily operations and corrections to process. Developed new operating variables, abated building fume problems, and developed project to eliminate stack mist.

Production Supervisor

October 1972 to July 1973

Shift responsibility for startup and operation

of Nitric Acid complex including AOP,

Denitration Units, and Nitric Acid

Concentrators.

January 1969 Sun Oil Company

toOperations Analyst

September 1972September 1971 to September 1972

Maintenance and reformulation of refinery linear programs. Preparation of refinery operating plans and budgets. Prepared

Military Jet Fuel bids. Various economic evaluations of refinery projects.

Process Engineer

April 1970 to August 1971

Reviewed daily operations of various refinery

units. Responsible for maximizing fired heater

efficiencies throughout refinery. Various

projects on process revamps.

Jr. Economics Engineer

January 1969 to April 1970

Linear programming to optimize refinery production and annual budgets. Long range economic programming. Developed method for

predicting gasoline blends from components. Revamped computersimulators.

Publicatons:McGregor, W., Bernard, T., and Feldman, A., "Total Recycle in an Industrial Phosphates Plant", Proceedings 6th Annual Industrial Pollution Conference, St. Louis, Mo., April 1978

Feldman, A., "Profit from Steam Trap Testing and Evaluation in a Large Plant", Power, July 1982

Feldman, A., "A Hazardous Waste Management Program - Olin Corporation", Proceedings of International Congress on Hazardous Materials

Management, Chattanooga, Tn., June 1987

Feldman, A., "Waste Minimization Programs –

What Can Go Wrong", Proceedings of CMA Waste Minimization Workshop, New Orleans, La., November 1987

Professional Affiliations:

Member AIChE

Member ASME

ViceChair ASME Committee on Hazardous Waste Incinerator Operator Certification

Chair ASME Sub-Committee on Hazardous Waste Incinerator Operator Certification Testing

Business Affilation:

Member Lower Bucks County Chamber of Commerce

Business/Education Committee

Personal Affilation:

Board Member Bucks County "Volunteers for

Homeless"

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