Wednesday, December 7, 2011

Basis for Denial of Re-Certificatio

As part of the re-certification process, DTSC considered the level of testing needed to determine
whether the treatments could be performed safely and effectively. DTSC concluded that Formalex
should be tested on actual wastes rather than only on unused 10% NBF. This was consistent with the
testing performed on another formaldehyde treatment technology evaluated by the program after the
initial certification of Formalex.
The manufacturer of Formalex claims that their technology can treat formaldehyde waste to render it
non-hazardous. DTSC was interested in ensuring that the technology reduced the toxicity, as well as
reduce the formaldehyde concentrations, of the wastes. Formaldehyde concentrations in the waste
were determined using U.S. EPA SW-846 Method 8315. Toxicity was determined using an acute
aquatic LC50
bioassay procedure specified in Title 22, California Code of Regulations, section
66261.24(a)(6) for hazardous waste classification in California. This method is also consistent with theintent of Title 22 California Code of Regulations (CCR) section 67450.20 for placement of certified
technologies in the conditional exemption permitting tier, as described in the Statement of Reasons for
that section.
The Formalex technology relies on chemical reactions to reduce the formaldehyde concentration in the
wastes. The reactions may produce unidentified reaction products with unknown toxicity. Therefore,
DTSC concluded that formaldehyde determinations and acute aquatic 96-hour LC50
bioassay toxicity
testing should be performed on the wastes both before and after treatment to assess the ability of the
technologies to reduce the formaldehyde concentration while also reducing the waste toxicity.
DTSC staff have prepared a report “Formaldehyde Treatment Technologies Re-Certification
Evaluation Report,” which summarizes the design of the field test and presents the test results. This
document is available upon request at the address shown above, or from the DTSC web site at

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