Welcome to the Department of Toxic Substances Control

Final Decision to Certify Hazardous Waste Environmental Technology


Katec, Inc.

Model 6000 Aerosolv® Aerosol Can Recycling System


The following is excerpted from:
CALIFORNIA REGULATORY NOTICE REGISTER
Published Weekly by the Office of Administrative Law
Register 99, No. 44-Z
October 29, 1999
pp 2123-2137


The California Environmental Protection Agency, Department of Toxic Substances Control (DTSC) has made a final decision to certify the following company's hazardous waste environmental technology listed below:

Katec, Inc.
P.O. Box 3399
Virginia Beach, VA 23454

Model 6000 Aerosolv® Aerosol Can Recycling System

Health and Safety Code section 25200.1.5 authorizes DTSC to certify the performance of hazardous waste environmental technologies. The purpose of the certification program is to provide an in-depth, independent review of technologies to facilitate regulatory and end-user acceptance. Only technologies that are determined to not pose a significant potential hazard to the public health and safety or to the environment when used under specified operating conditions may be certified.

DTSC makes no express or implied warranties as to the performance of the manufacturer's product or equipment. The end-user is solely responsible for complying with all applicable federal, state, and local regulatory requirements. Certification does not limit DTSC's authority to take any action necessary for protection of public health and the environment.

By accepting certification, the manufacturer assumes, for the duration of certification, responsibility for maintaining the quality of the manufactured equipment and materials at a level equal to or better than was provided to obtain certification and agrees to be subject to quality monitoring by DTSC as required by the statute under which certification is granted.

In accordance with the California Environmental Quality Act, an Initial Study was prepared that analyzed environmental impacts that may be caused by the certification decision (project). DTSC has prepared a Mitigated Negative Declaration based on the Initial Study and its determination that this project with mitigation measures would avoid or mitigate any effects to a point where no significant effect on the environment would occur. Copies of the Mitigated Negative Declaration and Initial Study are available for review at the address given below.

DTSC's proposed decision to certify was published on June 25, 1999 in the California Regulatory Notice Register 99, Volume No. 19-Z, pp. 1278-1291. Comments were received during the public review and comment period. Responses to comments received have been prepared, and minor changes have been incorporated into the final certification decision, where appropriate. Additional information supporting DTSC's final decision, including the Responses to Comments and the August 27, 1999 Draft Environmental Technology Verification Report, is available at:

California Environmental Protection Agency
Department of Toxic Substances Control
Office of Pollution Prevention and Technology Development
P.O. Box 806
301 Capitol Mall, 1st Floor Sacramento, California 95812-0806
(916) 322-3670

A description of the technology to be certified, the certification statement and the certification conditions for the technology of the company listed above follows.

Katec, Incorporated

Model 6000 Aerosolv® Aerosol Can Recycling System

Technology Description

The Katec, Inc. MODEL 6000 AEROSOLV® AEROSOL CAN RECYCLING SYSTEM (hereinafter referred to the Aerosolv® System) is a waste aerosol can puncturing and draining technology. The technology punctures and drains waste aerosol cans while collecting their liquid contents in a storage drum and treating gases and vapors with a carbon filter. Treated waste aerosol cans are recycled as scrap metal. Recycling of the emptied cans is a condition of this certification. The collected liquids and used carbon filters are classified as hazardous or non-hazardous waste and managed accordingly. The system consists of four components: the Aerosolv® Puncturing Unit, a liquid collection drum, a coalescing filter and flexible hose, and a carbon canister. The liquid collection drum, a standard 55-gallon closed-head drum, is supplied by the user. Katec also provides an instruction manual on how to operate and maintain the system. A Colorimetric Indicator was included in the evaluation, but is not part of the system being certified.

Aerosolv® Puncturing Unit. The Aerosolv® Puncturing Unit screws into the 2-inch bung hole of a standard 55-gallon drum (i.e., the liquid collection drum). To operate the Aerosolv® Puncturing Unit, the spray nozzle is first removed from an aerosol can, then the can is placed upside down into the top of the unit. A sliding top plate assembly is swung over the can and then depressed to push the can down against a flat silicone gasket inside the unit. After the aerosol can is secured in place, a spring-loaded handle on the unit is pushed down to pierce the dome of the can with a carbide-tipped puncture pin in a manner specified in the instruction manual. As the can is emptied, vapors and gases pass from the collection drum through the coalescing filter into the carbon filter. After the contents of the can have been allowed to drain (approximately 30 seconds to two minutes), the can is removed from the unit and placed in a separate container.

Replaceable seals are provided at two locations to prevent releases of gases and liquids during puncturing: (1) a flat annular shaped gasket composed of silicone is set within the unit to provide a seal around the shoulder of the inserted can, and (2) two Viton O-rings seal the annulus around the puncture pin, which is replaceable and housed in a Teflon sleeve. A primary function of the two Viton O-rings is to retain grease packing around the puncture pin for smooth operation.

The body, cap and handle of the unit are cast aluminum. A lock knob located on the side of the unit turns a set screw onto the slide bar of the sliding top plate assembly to secure the aerosol can in place. The sliding top plate assembly consists of the cap, slide bar and sealing knob. The sealing knob, located on top of the cap, is turned to press the aerosol can further down into the unit onto the silicone gasket to form a seal, and to push open a spring-loaded check valve at the base of the unit. The check valve has a flat Teflon® seal which when open allows the contents from the punctured can to pass into the collection drum. When the can is removed, the valve is intended to seat against the bottom of the unit preventing or reducing escape of vapors when the unit is not in operation.

55-gallon closed-head drum. Liquids released from the punctured aerosol can are collected in a standard 55-gallon liquid collection drum. To ensure adequate headspace for discharged gases, the drum is changed when it has reached 70% of capacity (a minimum of 17 gallons or 10 inches of headspace).

Coalescing Filter. The coalescing filter screws into the 3/4-inch bung hole of the liquid collection drum and is connected to the carbon filter inlet with 2-inch diameter hose. Gases and vapors from the punctured cans pass from the liquid collection drum through the coalescing filter prior to entering the carbon canister. The coalescing filter is intended to coalesce aerosol droplets such that they drain back into the liquid collection drum, and to allow only vapors and gases to pass into the carbon filter.

Carbon Filter. The carbon filter is used to treat gases and vapors that are generated from the puncturing and draining operation. It is constructed from a 30-gallon high-density polyethylene drum and contains three layers of activated carbon, each approximately eight to ten inches thick. The carbon layers are separated by a total of four 2-inch layers of Dual Denier fiber. According to Katec, a total of 41 pounds of 4-millimeter pelletized activated carbon is used in the filter.

Instruction Manual. An instruction manual includes procedures and conditions required for this certification for operation and maintenance of the technology.

Basis for Certification

Evaluation Approach. The evaluation of the Aerosolv® System was designed to provide the data necessary to draw conclusions on the technology's performance, reliability and safety. Additionally, the critical operating parameters and conditions related to the technology's performance, reliability and safety were to be identified. The evaluation included a review of supporting documents and information submitted by Katec which describes their technology and its intended operation and maintenance, and a field test to provide independent data on the technology's performance and safety. A key document which Katec submitted, the Aerosolv® 6000 Instruction Manual, was reviewed and will be revised as part of the certification process.

The field test was carried out at the U.S. Navy (Navy) Public Works Center, San Diego. The Navy is a Katec customer and agreed to provide facilities, staff, and waste aerosol cans from their hazardous waste storage facility for conducting the field test. Prior to commencing the field test, the Department of Toxic Substances Control (DTSC) prepared a Field Test Plan to identify specific field test objectives, data quality objectives, testing procedures, and roles and responsibilities for performing the field test. The Navy assumed overall responsibility for conducting the field test. DTSC staff provided independent oversight and were present to observe many, but not all, of the field test activities. The agreed-upon Field Test Plan specified that the Navy would record all measurements and observations made during the field test. Following the completion of the field test, the Navy submitted their report providing the field test data collected and a summary of field test results. The Navy also provided field log notes compiled by the Navy industrial hygienist during the field test. Additionally, DTSC staff observations made during the field test were included as part of the evaluation.

Previous versions of the technology which Katec has marketed did not contain the carbon filter component. Therefore, reliability and performance information was only obtained through the above referenced field testing. No data were available to assess long term reliability and performance of the specific Aerosolv® System being evaluated.

Field Test Objectives. The field test was designed to obtain quantitative data for verifying four specific objectives, and to provide an opportunity to observe the quality and reliability of the technology in operation. The four objectives are listed below.

  1. Removal Effectiveness. (a) Determine the ability of the Aerosolv® System to treat aerosol cans to less than 3.0% of the original can contents or capacity, the federal definition of an empty container; (b) Determine the Removal efficiency of the Aerosolv® System, the percent of the contents in untreated waste aerosol cans that the Aerosolv® System removes.
  2. System Capture Efficiency. Establish whether the Aerosolv® System captures the gaseous and liquid contents removed from the waste aerosol cans (DTSC used 90% as a capture efficiency target during field testing).
  3. Carbon Filter Effectiveness. (a) Determine the total mass of the contents from waste aerosol cans processed by the Aerosolv® System that results in carbon filter saturation; (b) Measure the total organic vapor concentrations in carbon filter breakthrough emissions to serve as the basis for establishing appropriate criteria for replacement of the carbon filter during operation of the technology; (c) Assess the adequacy of the procedures for determining when the carbon filter is spent and needs replacement.
  4. Assess Worker Health & Safety. Determine the capability of the Aerosolv® technology to operate in compliance with levels and standards established in state and federal regulations for protection of worker health and safety.

Aerosol Can Products Evaluated. Katec and the Navy requested that the performance of the Aerosolv® System be evaluated for three categories of aerosol can products: paints; hydrocarbon cleaners and lubricants; and chlorinated solvent cleaners. The Navy provided two lines of paint, manufactured by LHB Industries, St. Louis, MO, for testing: Eco Sure and So Sure. Eco Sure paints are a line of low VOC, high solids enamel and primer paints. So Sure paints are standard lacquer and enamel paints. Due to the wide variety of colors and dates of manufacture of paints selected by the Navy, it was not possible to predetermine with certainty all ingredients that might have been in the paints. The paints tested were found to contain a mixture of aromatic and aliphatic hydrocarbons such as toluene, xylenes, and naphtha; low and medium boiling point ketones such as acetone and methyl ethyl ketone; paint solids; and occasionally dichloromethane. Some of the paints included dimethyl ether propellant, while others included propane/butane/isobutane propellant. The Navy identified a Corrosion Preventative Compound (CPC) manufactured by LHB Industries to represent the hydrocarbon cleaners and lubricants. Field test results showed that the CPC contained a mixture of aliphatic and aromatic hydrocarbons, small amounts of chlorinated solvents, possibly some ketones, and Freon-11 and Freon-12 propellants. To represent the chlorinated hydrocarbon solvent cleaner for the field test, the Navy selected Brakleen, manufactured by CRC Chemicals, Warminster, PA. The Brakleen contained tetrachloroethene, small amounts of trichloroethene, and carbon dioxide propellant, along with other, undetermined ingredients.

Field Test Activities and Results. A series of seven (7) test runs were conducted to evaluate the Katec Aerosolv® System for treating the three types aerosol can products, three on paints and two each on the CPC and Brakleen. During the seven test runs a total of 2270 waste aerosol cans were punctured and drained using the Aerosolv® technology. This included 1690 paint aerosol cans, 350 CPC aerosol cans, and 230 Brakleen aerosol cans. Averages of can fullness were 26%, 11% and 33% for the three paint test runs, 42% and 87% for the two CPC test runs, and 22% and 100% for the two Brakleen test runs.

Two Total Vapor Analyzers (TVAs), operating in the Flame Ionization Mode, were used during each of the seven field test runs while aerosol cans were being punctured and drained. The TVA's were used to measure and record total hydrocarbon emissions concentrations at a fixed location near the puncturing unit and at the carbon filter exhaust port. The fixed TVA at the Aerosolv® Puncturing Unit was placed in the downwind direction at an elevation no more than 6 inches above the elevation of the puncturing unit. A drum scale was used to weigh the Aerosolv® System at the beginning and end of each test run and whenever the carbon filter was changed out. The system was weighed in two parts: (1) the Aerosolv Puncturing Unit, liquid collection drum and coalescing filter, and (2) the carbon filter, Colorimetric Indicator and connecting hose. All waste aerosol cans used for the seven test runs were weighed both before and after being punctured and drained. A wind speed sensor with a 1 mph threshold was set to continuously monitor windspeed during each of the test runs while aerosol cans were being punctured and drained.

In addition, Navy Industrial Hygiene staff collected area and breathing zone air monitoring samples to evaluate worker exposure during operation of the Aerosolv® System. OHSA Methods 07 and 48 were used for sample collection and analysis. For each of the three product types, long and short term exposure samples were analyzed for the target constituents expected to be contained in the specific aerosol can product being tested. Details on all specific activities conducted by the Navy Industrial Hygiene staff during the field test and their corresponding results are presented in the Navy's January 28, 1999 report, "Aerosolv® Aerosol Can Recycling Technology, Field Test Demonstration, Summary of Results, August 5, 1998 - November 29, 1998, Navy Public Works Center Environmental Department, San Diego".

During each of the three sets of test runs composite liquid samples were collected from the liquid collection drum and analyzed by independent laboratories using EPA Method 8260, a GC/MS analysis. Results from the liquid sample analyses showed that the aerosol can products treated included chemical constituents not included in the Navy's area and breathing zone air monitoring. For the paint test runs these include dichloromethane, 4-methyl-2-pentanone (methyl isobutyl ketone), and tetrachloroethene, for the CPC test runs this included dichloromethane, and for the Brakleen test runs this included 1,1,1-trichloroethane. DTSC's certification includes specific conditions 2, 3 and 4 to control the nature of the constituents to be treated. The results for each of the four established objectives of field test were as follows:

1a. Removal Effectiveness.

The field tests evaluated the capability of the Aerosolv® System to treat aerosol cans to less than 3.0% of the original can contents, the federal definition of an empty container. The 3% criterion was evaluated using a subset of all the cans tested. For each aerosol can product category evaluated 75 cans were randomly selected from the inventory of treated aerosol cans. The selected cans were cleaned to remove any remaining residuals after treatment, then dried and weighed to determine their tare weights. Removal effectiveness was calculated for each can based on its weight before and after treatment and its tare weight. Because of discrepancies in the recorded pre- and post-treatment weights, several of the selected cans had to be excluded from the analysis.

The upper 95% confidence limit of the mean fraction (percentage) of the original contents remaining in the treated cans was determined for each product category. The objective was considered met if the upper 95% confidence limit of the mean was less than 3%, the federal definition of an empty container.

Paint Product Category. Based on the set of 73 randomly selected cans, 5 of 19 cans from Test Run #1, and 1 of 13 cans from Test Run #3 had greater than 3% of the original can contents remaining after treatment. All 41 cans from Test Run #2 contained less than 3% after treatment. The mean and standard deviation for the fraction remaining in the aerosol cans after treatment were determined for each paint test run. The upper 95% confidence limit of the means were calculated to be 3.41%, 0.99%, and 2.25% in Test Runs #1, #2, and #3, respectively. Thus, in one of the three paint test runs the Aerosolv® System did not meet Objective 1a. For Test Run #1 the confidence was only 77% that the mean was 3% or less (i.e., the upper 77% confidence limit of the mean was 3%). The varied removal effectiveness may be due to the differences between the types of waste aerosol paints treated in the three test runs. Test Runs #1 and #3 involved the treatment of Eco Sure brand paints which include high solids paints, while Test Run #2 involved treatment of So Sure brand paints with lower solids content. Additionally, the waste aerosol cans treated during Test Runs #1 and #3 averaged 21.8% full and 19.1% full, respectively, which were significantly fuller than the average 9.1% fullness of cans treated during Test Run #2.

The Field Test Plan specified three replicate test runs. As discussed above, the aerosol cans treated during the three test runs differed in terms of the products tested and the average fullness. Therefore, it is not appropriate to combine the results from all three test runs. Since the aerosol cans treated in Test Runs #1 and #3 appear similar it may be appropriate to combine these results. The upper 95% confidence limit of the mean for Test Runs #1 and #3 combined is 2.81%. Thus, specific condition 5 restricting the use of the technology to cans which are less than 25% full was imposed.

Hydrocarbon Lubricant & Cleaners Category. Field test results show that the Aerosolv® System removed residuals in CPC aerosol cans to an average of 0.84% of their original contents (upper 95% confidence limit), well below 3%, the federal definition of an empty container.

Chlorinated Solvent Category. The Field Test Plan required that all cans selected for this determination contain significantly greater than the 3% criterion or federal definition of an empty container. Field test data indicate that the Brakleen aerosol cans selected by the Navy from Test Run # 6 for determining removal effectiveness contained an average of less than 2% of their original net contents. Therefore, the aerosol cans selected would have achieved Objective 1a before treatment and no conclusions can be drawn from this data regarding removal effectiveness. However, a review of the pre and post-treatment weights of fuller (>3%) Brakleen aerosol cans treated during Test Runs #6 and #7 and the tare weight data for Brakleen aerosol cans would indicate that the Aerosolv® System removed or emptied the residuals to below the 3% criterion.

1b. Removal Efficiency

Removal efficiency, the percent of the waste aerosol can contents that the Aerosolv7 System removed, was evaluated for each product category. The 95% lower confidence limit of the mean removal efficiency for each product category was determined based on the results for the groups of randomly selected treated cans from each test run.

Paints Aerosol Can Products. The lower 95% confidence limit of the mean removal efficiency determined for paint test runs was 77.2% in Test Run #1, 81.6% in Test Run #2, and 83.7% in Test Run #3.

Hydrocarbon Lubricant & Cleaners Category. The lower 95% confidence limit of the mean removal efficiency determined for the two CPC test runs was 97.8% .

Chlorinated Solvent Category. The lower 95% confidence limit of the mean removal efficiency determined for one of two Brakleen test runs was 61.8%. This relatively low result is due to the near-empty waste aerosol cans selected from Test Run # 6 for this analysis. The calculated removal efficiency becomes proportionately less when the denominator (can fullness) is reduced, as is the case with near-empty cans.

2. System Capture Efficiency.

System capture efficiency, the percent of the contents removed from the cans that the Aerosolv7 System captures either as liquids or adsorbed on the carbon filter, was determined for each product type. Using the weights of the aerosol cans before and after treatment and weights of the liquid collection drum and carbon filter assemblies, capture efficiency was measured to within +/- 1% for each test run conducted. The lower 90% confidence limit of the mean capture efficiency was determined for each set of test runs.

Paint Products Category. The capture efficiencies measured for paints in Test Runs #1, #2 and #3 were 88.5%, 84.0% and 94.9%, respectively. The mean of the capture efficiencies measured for the three paint test runs was 89.1% with a standard deviation of 5.5% and a lower 90% confidence limit of 83.2%.

Hydrocarbon Lubricant & Cleaners Category. The capture efficiencies measured for CPC products in Test Runs #4 and #5 were 96.9% and 97.0%. The mean capture efficiency for the two CPC test runs was 96.9% with a standard deviation of 0.1% and a lower 90% confidence limit of 96.8%.

Chlorinated Solvent Category. The capture efficiencies measured for Brakleen in Test Runs #6 and #7 were 97.0% and 99.0%. The mean capture efficiency for the two Brakleen test runs was 98.0% with a standard deviation of 1.5% and a the lower 90% confidence limit of 94.9%.

3. Carbon Filter Effectiveness.

The Field Test Plan specified changeout of the carbon filter (i.e., replacement) when the total hydrocarbon concentration in the exhaust reached 10% of the inlet concentration, or when concentration levels specified in the field test Health & Safety Plan for protection of worker health and safety were exceeded. When the changeout criterion was reached, the carbon was considered to be saturated and to have reached its useful capacity.

For test runs involving paints and CPC's the carbon filter inlet concentrations were expected to approach 100% as propellants and vapor displace the air initially present in the system. For these test runs the carbon filter was replaced when the total hydrocarbon concentration in the exhaust reached 10% or 100,000 ppm. For the test runs involving Brakleen composed primarily of tetrachloroethene and carbon dioxide propellant, the maximum inlet concentration was expected to be 20,000 ppm based on tetrachloroethene's vapor pressure of 14 mm Hg. Thus, for the Brakleen tests runs the carbon filter was to be replaced when exhaust concentrations measured 2000 ppm with the TVA FID.

A new unused carbon filter and Colorimetric Indicator were installed at the start of each set of test runs for each product type, and during each test run when the carbon changeout criterion was reached. Prior to use of the carbon filter, the carbon filter assembly (carbon filter, Colorimetric Indicator and assembly hose) was weighed. During each test run the TVA FID was used to measure total hydrocarbon concentrations between the carbon filter exhaust port and the Colorimetric Indicator. When concentrations exceeded 2000 ppm during Test Runs #1 through #5, the TVA monitor was equipped with a 50:1 diluter and recalibrated. With the 50:1 diluter installed, a TVA reading of 2000 ppm indicates an actual concentration of 100,000 ppm. When exhaust concentrations consistently exceeded 100,000 ppm or 10% of the inlet concentration, the carbon filter was considered spent and replaced. The spent carbon filter assembly was then disconnected and weighed to determine the mass of vapors and gases which had been adsorbed by the carbon filter. The test run was continued after a fresh carbon filter and Colorimetric Indicator were installed. Use of a carbon filter was continued through a subsequent test run(s) for the same product type until the changeout criterion was reached. During each test run, the specific aerosol cans treated while each carbon filter was being used were recorded in the Navy Industrial Hygienist's field log. Field Test results for carbon filter effectiveness for the three product types are discussed below.

Paint Aerosol Can Products. During the paint test runs a total of 5 filters were saturated and required changeout. The average (mean) amount of aerosol can contents processed by the Aerosolv® System before each filter became saturated was 33.7 lbs. with a standard deviation of 8.9 lbs. Therefore, the system can process 25.2 lbs of paint aerosol can contents before the filter is saturated (lower 90% confidence limit).

The average (mean) number of aerosol cans processed by the Aerosolv® System before each filter became saturated was 313 cans with a standard deviation of 131 cans. Using the number of cans to assess filter capacity without indicating the fullness of the cans processed would be misleading. The average fullness of cans processed for each of the filters saturated varied from 9% for Filter #3 to 30% for Filter #9. The average fullness of the 1564 cans processed during the use of the 5 saturated carbon filters was 17%. Therefore, the system can process at least 187 waste aerosol paint cans (lower 90% confidence limit) with an average fullness of 17% before the filter is saturated.

Carbon Capacity was also evaluated in terms of mass of volatiles from aerosol paint products adsorbed prior to changeout (saturation). For the saturated filters the average mass adsorbed was 6.4 lbs with a standard deviation of 0.9 lbs. Therefore the carbon filter can adsorb 5.6 lbs before it becomes saturated (lower 90% confidence limit).

Hydrocarbon Lubricant & Cleaners Category. Only one of the two carbon filters used, filter # 5, was saturated during the two CPC test runs. This filter adsorbed 12.1 lbs while the Aerosol® System processed 250 waste aerosol cans with an average fullness of 42% before this carbon filter was replaced. Filter #6 which was also used did not reach capacity at the end of Test Run #6. At the end of this test run 100 waste aerosol cans with average fullness of 87% had been processed and the filter had adsorbed 11.3 lbs. These results indicate that the carbon filter had about a 60% greater capacity for this type of aerosol can product than for the paint products tested. This is consistent with the fact that the CPC tested contained halogenated propellants which are expected to adsorb strongly to carbon. Other hydrocarbon lubricant and cleaner products may not contain propellants which adsorb strongly to carbon, and consequently carbon filter capacity for these products would be less.

Chlorinated Solvent Category. Only one carbon filter was used during the two Brakleen test runs and it did not reach saturation. At the end of the two test runs during which this filter was used, 230 waste aerosol cans with 38% average fullness had been processed. Only 1.8 lbs were adsorbed onto the filter, indicating it had more capacity. These results would be expected for Brakleen aerosol can products since (1) the propellant, carbon dioxide, is not adsorbed by carbon, and (2) the primary ingredient, tetrachloroethene, is a relatively high boiling liquid which would not be expected to volatilize a great deal over the short duration of these two test runs.

Carbon Breakthrough Emissions. The total hydrocarbon concentrations in carbon filter emissions at breakthrough were measured to serve as the basis for establishing appropriate criterion for replacement of the carbon filter during operation of the technology. Generally, once concentrations measured in the carbon exhaust reached a few hundred ppm there was a relatively rapid increase in concentration to the 100,000 ppm carbon changeout criterion. For carbon filter #1, for example, carbon filter emission concentrations reached 200 ppm after 291 cans, but then reached 100,000 ppm in about 60 minutes of operation while processing only 27 additional aerosol cans.

Colorimetric Indicator. Additionally, Katec's Colorimetric Indicator was periodically checked to determine if any significant color change occurred which would indicate breakthrough and that the carbon filter had reached capacity. The Colorimetric Indicators that were used never indicated any observable color change during their use in all of the field test runs. Katec claimed that their Colorimetric Indicator could be used to monitor the carbon filter and to indicate when the carbon filter has become saturated and needs to be replaced. The operator is supposed to check a clear window in the side of the cartridge for a color change. A label next to the window shows adjacent black and bright pink colors which are supposed to represent whether the cartridge is expended or not. Katec refers to the Colorimetric Indicator as a "carbon cartridge." The indicator material consists of hydrated zeolite (clinoptilolite) granules impregnated with 6% by weight of potassium permanganate. The indicator material is manufactured by Cameron Yakima, Inc. and is sold primarily for odor control. Potassium permanganate, purple in color, is an oxidizing agent which generally reacts more readily with organic compounds containing oxygen than with other compounds present in the cans tested. The permanganate reaction product is dull brown in color, not black as claimed by Katec. Based on information from the manufacturer of the granules, the indicator should react well with ethers, such as dimethyl ether propellant; with ketones, such as acetone or methyl ethyl ketone; and with alcohols, such as isopropanol. It would react poorly with aromatic compounds such as xylenes; with chlorinated hydrocarbons such as tetrachloroethene or Freon-12; or with aliphatic hydrocarbons such as propane propellant or octane.

During the seven field test runs six carbon filters were replaced. During every test run the carbon filter's Colorimetric Indicator was periodically checked while being used and upon changeout to determine if any significant color change occurred. DTSC staff field notes as well as the Navy Industrial Hygienist's field log document that there were no visual color changes observed in the indicators during any of the test runs to indicate that a carbon filter needed to be replaced. According to Katec, Inc. the color of the media in the indicator's display window changes from a magenta to black when the filter becomes saturated and needs to be replaced. This did not occur.

The results are conclusive for paint aerosol can products and for hydrocarbon lubricants and cleaners that the Colorimetric Indicator is not an appropriate device for monitoring the carbon filter to determine when filter is saturated (i.e., when the carbon filter must be replaced). For halogenated aerosol can products the effectiveness of the indicator could not be determined because the carbon filter used for both Test Runs # 6 and #7 involving Brakleen aerosol cans never reached its capacity nor had significantly high levels of breakthrough emissions. Consequently, the Colorimetric Indicator is not approved as part of this certification.

4. Worker Health and Safety.

DTSC Industrial Hygiene staff participated in the development of the Field Test Plan, reviewed the Site Health and Safety Plan for the field test, and reviewed the report that the Navy submitted providing the field test data collected and a summary of the field test results. Results of this review are presented in a March 17, 1999 DTSC Memorandum prepared by DTSC Industrial Hygiene staff. The conclusions of this review with respect to the specific objectives follow.

Objectives 4a and 4b. Determine Worker Exposure Levels. The data do not support the objective that occupational exposed individuals will not be exposed beyond occupational exposure levels. It appears during the field test that the chemical speciation monitoring does not indicate an overexposure. However, the chemical speciation monitoring of the worker was done primarily upwind, did not fully reflect the aerosol can contents, and is not readily correlated to the direct read instruments.

Objective 4c. Determine Whether Emissions Exceed 10% of the Lower Explosive Limits (LEL). The data submitted by the Navy is not conclusive that emissions from operations of the Aerosolv® System limit exposure to less than 10% of the LEL. Only results of the TVA 1000 monitoring, not a direct read LEL meter, were reported. The relative response of the TVA 1000 to different gases and propellants (e.g., propane and butane) varies and therefore the TVA data are considered qualitative and not conclusive.

Objective 4d. Determine Effectiveness in Preventing Liquid Releases. If the spring-loaded handle is slowly released after puncturing the aerosol can and the seals and O-rings are properly maintained, the unit will be effective in preventing releases of the liquid contents of the aerosol cans.

DTSC Industrial Hygiene staff also assessed the occupational health and safety in the operation of the Aerosolv® System. A number of occupational health and safety recommendations were made that are conditioned on operation of the Aerosolv® System outdoors (no structures / walls near the unit) with cans not more 25% full, and not containing herbicides, pesticides adhesives or corrosives ( as defined by Title 22). These recommendations have been incorporated into specific conditions 2, 5, 8 and 9 of this certification.

Field Test Observations on Aerosolv® System Performance and Design

During the field test, observations were made on how the Aerosolv® System and its components were operated and maintained, and potential problems with performance and design were identified.

Puncturing and Draining Operation. Gradually releasing the handle allows the aerosol can contents to discharge through the bottom of the unit into the liquid collection drum. The handle must be released slowly to avoid rapid release of the can contents and the potential for uncontrolled releases of the gases and liquids. For viscous materials such as paint, the can should be adequately shaken before puncturing and more than one puncture hole may be necessary. To make additional drain holes the can is rotated and punctured again before being removed from the unit.

Lock and Sealing Knobs. The lock knob on the first Aerosolv® Puncturing Unit failed after approximately 320 cans and failed on the second unit after approximately 1000 cans. In both cases the puncturing unit was rendered unusable and had to be replaced so that the field test could continue. The sealing knob failed during Test Run #2 but the unit was not replaced at that time. The steel screws associated with the lock knob and sealing knob screw into a threaded hole in the cast aluminum body and cap of the unit; no threaded steel sleeves or inserts are used. Consequently, the threaded holes in the cast aluminum tend to strip out with repeated tightening and loosening of the knobs. When this occurs, the body or cap requires replacement. Katec, Inc. has advised DTSC that the manufacturing process has been modified for future Aerosolv® Puncturing Units to install HeliCoil inserts in the body and cap to prevent this problem from occurring.

Puncture Pin. DTSC staff inspected the Aerosolv® Puncturing Units used at the end of the field test. On two of the units, the puncture pin protruded beyond the inner edge of the can shoulder gasket. On these units the puncture pin appears to impede the insertion of the aerosol can into the barrel of the unit, preventing the can shoulder gasket from sealing adequately. During the field tests (8/25/98) the operator experienced difficulty in getting a newly installed unit to work properly, most likely due to this problem. Because the aerosol can must be pushed down far enough into the barrel of the unit to cause the spring-loaded check valve to open, such a condition could prevent proper opening of the check valve, thereby restricting flow of the liquid and gases released during puncture into the liquid drum below.

Check Valve. The check valve is composed of a spring-loaded, Teflon® disk. Due to the material's rigidity, the disk does not form a positive seal along the contact surface at the base of the Aerosolv7 unit. Consequently, release of head-space volatiles can occur when the system is idle or during periods of non-use. The liquid collection drum assembly which includes the attached Aerosolv® Puncturing Unit, was weighed before and after periods of non-use to determine the amount of such losses: Test Run #3: 0.4 lbs lost between 9/22/98 and 10/7/98; Test Run #4: 0.3 lbs lost between 8/25/98 and 8/28/98; Test Run #5: 0.6 lbs lost between on 8/28/98 and 8/31/98.

O-ring Wear and Compatibility. During inspection of the units, severe wear of the inner O-ring on Aerosolv® Puncturing Unit #2 was observed. This particular unit had been used for puncturing paint cans and was replaced when the lock knob failed after puncturing approximately 1000 cans. The O&M Manual specifies that the O-rings are to be inspected every 500 cans. Katec indicates that the composition of the O-rings, is Viton®, a fluorocarbon rubber manufactured by E.I. Dupont de Nemours Company (Dupont). According to Dupont, Viton® may not be appropriate for use with certain constituents found in aerosol cans, such as ketones (e.g., acetone, MEK MIBK, and MIAK) and low molecular weight esters and ethers, (e.g., dimethyl ether, a commonly used propellant). If the O-rings fail, there is a potential for release of can contents during puncturing through the annular space around the puncturing pin. Consequently, O-ring maintenance should be performed according to the manufacturer's recommendations.

Silicone Gasket Performance and Compatibility. According to Katec's submittals, the annular flat-shaped gasket which is intended to provide a seal around inserted aerosol can is composed of silicone rubber. Information obtained from one distributor indicates that silicone is incompatible with a wide variety of organic solvents, including chlorinated solvents. During the tests of the technology on CPC and on Brakleen, the gasket swelled and deformed. The deformation was significant enough to prevent the can from seating properly in the unit and the gasket had to be replaced twice during the CPC test runs and twice during the Brakleen test runs. Consequently, use of chlorinated solvents is not included in this certification.

Carbon Filter Construction. At the end of the field test, the top of a carbon filter was removed to observe the composition and construction of the carbon filter media. The fiber layers appeared to be poorly placed in the filter. Void spaces result in the carbon filter due to the placement of the fiber support matrix that separates the layers of carbon fiber and a mismatch between their square shape and the circular cross-section of the container. As a consequence, there is potential for short circuiting of the gases in the carbon bed which may shorten the time to breakthrough. Consequently, the criteria in specific condition 14 regarding carbon filter monitoring and changeout were added.

Conclusions

  1. Removal to 3% Capacity. Based on field testing results the Aerosolv® System was effective in six of the of the seven test runs in removing the residual contents in waste aerosol cans to below 3% of their original net contents (upper 95% confidence limit), the federal definition of an empty container. For the one paint test run which did not meet Objective 1a, Test Run #1, the Aerosolv7 System removed the residual contents to 3.41% (upper 95% confidence level). The Aerosolv® System was less effective in removing residuals from paint products than for the other two product types tested. Lower removal effectiveness is expected for paint products due to their higher solids content. Additionally, the two paint test runs involving fuller aerosol cans showed higher percent residuals remaining. Because the aerosol cans treated during the three paint test runs differed in terms of the products tested and the average fullness, it is not appropriate to combine the results from all three test runs. Since the aerosol cans treated in Test Runs #1 and #3 appear similar it may be appropriate to combine these results. The upper 95% confidence limit of the mean for Test Runs #1 and #3 combined was determined to be 2.81%.
  2. Capture Efficiency. Based on field testing results the system capture efficiencies for the paints, CPC's and Brakleen were 83.2%, 96.8% and 94.9%, respectively (lower 90% confidence limits). These results correspond to 16.8% of the paints, 3.2 % of the CPC's and 5.1% of the Brakleen removed from the cans being lost to the atmosphere.
  3. Carbon Filter Effectiveness. The carbon filter was effective in capturing emissions from Aerosolv® System during the puncturing and draining aerosol cans. Based on field test results, however, the capacity of the carbon filter appears limited in terms of the amount of aerosol can contents that the Aerosolv7 System is able to process before significant breakthrough emissions occur. The field test results also indicate that the capacity of the carbon filter to adsorb volatile organic emissions was about 60% greater for the CPC products tested than for the paint products tested. However, other hydrocarbon lubricant and cleaner products may not contain propellants which adsorb strongly to carbon, and consequently carbon filter capacity for these products would be less. Although a filter was not saturated during the two Brakleen aerosol product test runs, the relatively low mass of tetrachloroethene adsorbed onto the carbon filter is an indication that a larger number of cans of this product can be treated prior to breakthrough than for the other two products tested. The field test results show that the Aerosolv® System can process at least 187 waste aerosol paint cans (lower 90% confidence limit) with an average fullness of 17% before the filter is saturated. Plots of the breakthrough curves indicate that the emissions levels increased rapidly as the emissions levels approach the changeout criterion.
  4. Carbon Filter Monitoring. The Colorimetric Indicator did not work as claimed and should not be used to monitor the carbon filter for breakthrough. Based on the field testing experience, the best approach to determine when to replace the carbon filter is to continually monitor the carbon filter exhaust with a TVA-FID monitor (or equivalent). The next best approach would be to weigh the carbon filter before and during use to determine when it has reached capacity. Because of the varied fullness and quantities in waste aerosol cans products, the use of can counting to monitor the carbon would be a more difficult method for monitoring the carbon. If a TVA-FID is used to monitor the carbon exhaust, the monitoring should be continuous to detect the rapid increase in emissions after exhaust concentrations reach a few hundred ppm.
  5. Katec Aerosolv® Puncturing Unit. Based on observations during the field test, certain mechanical components of the Aerosolv® System lack reliability. The lock knob failed on one Aerosolv® Puncturing Unit after less than 350 cans and failed on another after approximately 1000 cans. In each case, the failure rendered the unit inoperable. On another unit, the puncture pin was observed to protruded into the barrel of the unit when in the retracted position, preventing proper operation.
  6. Katec Aerosolv® System Compatibility with Aerosol Can Products. Based on observations made during the field test, the Aerosolv® System is not compatible with compounds present in chlorinated solvent products or with hydrocarbon cleaners and lubricants which contain chlorinated propellants. The hydrocarbon cleaner/lubricant used during the field test contained Freon propellants as well as Freon-113 solvent, while the Brakleen product contained tetrachloroethene. For these product types the gasket in the unit swelled such that a can would not seal properly before puncturing. Therefore the conditions of certification preclude the use of the technology for aerosol products containing these types of products.
  7. Liquid Collection Drum. The 55-gallon liquid collection drums used during the field test were never filled to more than 29% of their capacity. The Instruction Manual indicates that the liquid collection drum must be replaced when it reaches 70% capacity. This never occurred during the field tests. Therefore the technology's performance when the 55-gallon drum had a minimum of 30% headspace was not evaluated during the field test. Headspace of 30% would mean approximately 2.5 pounds per square inch higher pressures in the liquid collection drum during puncturing operations and consequently a higher potential for emissions around the puncturing unit's gasket and seals. Therefore, certification conditions specify that the technology may only be used with a 55-gallon drum which meets DOT specifications for the collected liquids, and that the drum shall not be filled to to more than 70% of its capacity. Katec's instruction manual indicates that the a 30-gallon drum may also be used. DTSC only established the system's performance with the 55-gallon size drum. Additional testing of the system 30-gallon drum would be required to evaluate its performance before certification could be extended to include a 30-gallon drum.
  8. Worker Health and Safety. Based on a review of the field test results, the DTSC industrial hygienist was unable to conclude that potential exposures will not occur in the absence of appropriate engineering and administrative controls, or personal protective equipment. Therefore, specific conditions have been included in the certification to address potential health and safety concerns.

Certification Statement

Under the authority of Health and Safety Code section 25200.1.5, the Katec, Inc. Model 6000 Aerosolv® Aerosol Can Recycling System is hereby certified as a hazardous waste treatment technology subject to the specific conditions including the limitations/disclaimer set forth in the Certification Notice as published in the California Regulatory Notice Register on October 29, 1999, Register No. 99, Volume No. 44-Z, pages 2123-2137. The technology is certified for puncturing and draining waste aerosol cans containing paints and hydrocarbon lubricants and cleaners. Field test results show that the Katec Aerosolv® System treated hazardous waste aerosol cans to an average of less than 3% residual contents in two test runs with a Corrosion Preventative Compound product, and in two out of three test runs with paint products. In addition the system has been shown to be capable of capturing at least 83.2% of the liquid and gaseous contents removed from these aerosol can products. The process generates emptied aerosol cans intended for recycling as scrap metal. The collected liquids and contaminated carbon must be classified as hazardous or non-hazardous waste and managed accordingly. Air emissions resulting from the process are subject to regulation by the local air pollution control or air quality management district. Users are subject to compliance with all applicable federal, State and local requirements.

Limitations of Certification

DTSC makes no express or implied warranties as to the performance of the Katec Aerosolv® Aerosol Can Recycling System. Nor does DTSC warrant that the Aerosolv® System is free from any defects in workmanship or materials caused by negligence, misuse, accident or other causes.However, DTSC believes that the Aerosolv® System can be used in accordance with the conditions specified in this certification notice to achieve the results specified herein.

This certification is limited to use of the Aerosolv® System to treat aerosol cans containing paints or hydrocarbon lubricants/cleaners provided the ingredients do not include chlorinated solvents or Freon or other halogenated propellants.

Specific Conditions

  1. Requirement to Follow Specified Conditions. The user shall follow all conditions specified in this certification, in the California Health and Safety Code, including but not limited to sections 25201.14(a), 25201.14(c), 25201.5(d) and (e).
  2. Limitation to Specified Types of Aerosol Can Products. Use of the technology under this certification is limited to aerosol can products containing paints, hydrocarbon lubricants and hydrocarbon cleaners. The technology is not certified to treat aerosol cans containing chlorinated solvents, pesticides, herbicides, alkaline or acidic corrosives, or adhesives or resins. A copy of the MSDS for all products treated shall be reviewed for each product and maintained onsite and available for inspection.
  3. Limitation to Non-Halogenated Products. The certified technology shall not be used for treating aerosol can products which may contain chlorinated solvents or a Freon® or other halogenated propellant. The user shall review the MSDS for each product to ensure that products containing any halogenated organic compounds are not treated.
  4. Identification of Aerosol Can Products. Each aerosol can must be adequately labeled to enable identification of the can contents and the proper MSDS so that specific conditions 2 and 3 shall be met.
  5. Limitation on Fullness of Aerosol Cans Being Treated. Use of the certified technology shall be limited to waste aerosol cans which are less than 25% full. The user shall follow the procedures specified in the Katec Aerosolv® 6000 Instruction Manual to determine the fullness of each aerosol can prior to treatment.
  6. Draining of Aerosol Cans. In accordance with title 22, CCR, section 66261.7(b)(1), each treated aerosol can shall be fully drained such that no hazardous material can be poured or drained from the aerosol can when the can is held in any orientation (e.g., tilted, inverted, etc.).
  7. Limitation on Location of Operation. The certified technology shall not be operated within a 40 meter distance from the facility boundary, fence line or property line. Additionally, a certified technology shall not be operated within an 80 meter distance of any other Aerosolv7 System which may be operating at the same facility or location.
  8. Safety Instructions for End Users. Katec shall specify the following safety instructions in the Katec Aerosolv® 6000 Instruction Manual; users shall adhere to these instructions when operating the technology:
    1. The user shall ensure that both the Aerosolv® Puncturing Unit and the 55-gallon drum are bonded and grounded. If a material is used between the threads of the Aerosolv® Puncturing Unit and a metal 55-gallon liquid collection drum, the material shall be conductive (not a potential insulator such as Teflon tape) unless proper bonding is provided between these components or between each component and ground. If a non-conductive plastic 55-gallon liquid collection drum is used, the user shall determine whether a ground wire reaching the liquid inside the drum is needed to dissipate any static charge generated in accumulated liquids.
    2. The operator shall wear appropriate personal protective equipment including use of approved respiratory equipment based on the specific conditions and chemical monitoring at the job site.
    3. The operator shall utilize safety goggles and appropriate protective clothing to provide splash protection, and wear gloves compatible with the ingredients in the cans and the work activities conducted.
    4. The user shall operate the technology out-of-doors in an open, well-ventilated area sufficiently distant from any walls or other structures such that air flow is not impeded. Additionally, the operator shall stand in a position upwind of the Aerosolv® System, and use appropriate site-specific engineering and administrative controls. A flag or other simple device shall be used to monitor wind direction during operation of the technology.
  9. The operator shall be advised that emissions from the carbon filter exhaust and fugitive emissions near the Aerosolv® Puncturing Unit may at times exceed the lower explosive limit. As carbon filter emission concentrations approach the 100,000 ppm changeout criterion the lower explosive limit will generally be exceeded. The operator shall use appropriate engineering and administrative controls to ensure adequate protection from fire and explosion.
  10. Compliance with Worker Health and Safety Laws. Operation of the Aerosolv® System must be in compliance with all federal, state and local regulations relating to the protection of worker health and safety. In California these include, but are not limited, to Cal-OSHA and OSHA requirements.
  11. Compliance with Proposition 65. In California, the operator shall take all steps necessary to comply with the provisions of The Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) including, but not limited to, applicable warning requirements.
  12. Notification Requirements. Each user shall comply with the notification requirements specified in Health and Safety Code sections 25201.14(c)(2) and 25201.5(d)(7) and (8). In addition, at the time of notification a copy of these notifications shall be submitted to the Department of Toxic Substances Control, Office of Pollution Prevention and Technology Development, Technology Certification Program, P.O. Box 806, Sacramento, CA 95812-0806.
  13. Notification to Local Air Districts. Each user shall notify the applicable Air Pollution Control District or Air Quality Management District at least 60 days in advance of any operation to advise these agencies of the use of the Aerosolv7 units within their jurisdictions. Each user shall document that such notice has been given to the local districts and that the operation is in compliance with local air district requirements.
  14. Personnel Training. The operator shall be properly trained on how to safely and effectively operate and maintain the Aerosolv® System. In California, the training shall be conducted and documented in accordance with the personnel training requirements specified in title 22, CCR, section 66265.16.
  15. Criteria for Changeout of the Carbon Filter. The user shall monitor the carbon filter to determine if capacity has been reached. Use of the Katec Colorimetric Indicator for this purpose is not appropriate. The user shall use one of the following alternative methods:
    1. Continuously monitor total hydrocarbon concentrations in the carbon exhaust port with a Flame Ionization Detector (FID). The FID shall be placed at the exit of the carbon and operated in a manner such that it measures the concentration of gases exiting the carbon without dilution from outside air. The carbon filter shall be changed when the total hydrocarbon concentrations reach 100,000 ppm. The FID shall be calibrated and operated based on the relative responses of the constituents in the cans so as to avoid under-reporting of the actual concentration in the gases at the carbon exit. The FID shall not be operated outside its linear range. For the purpose of monitoring the carbon exhaust, each Aerosolv® System shall be equipped with a 12-inch long 3/4-inch diameter sampling tube which screws into the 3/4 inch bung hole of the carbon canister. A sampling port for the FID monitor shall be located in the tube, 1 inch vertically above the bung hole of the carbon canister; or
    2. Weigh the carbon filter during operations and replacing it when a weight increase of 5.6 lbs. over its initial unused (tare) weight is measured. The tare weight shall be marked on the carbon filter prior to use. After a new filter has been installed and used for a period of 3 hours, the weight of the filter shall be measured and recorded at a minimum on an hourly basis; or
    3. Log the number of cans treated and limit the number of aerosol cans processed per filter to 200.
  16. Maintenance of the Liquid Collection Drum and Carbon Filter. A shut-off valve shall be installed between liquid collection drum exit port and the connection line to the carbon filter. At the end of each day's operation or whenever the Aerosolv® System is not in use, the bung holes for the liquid collection drum inlet and the carbon filter outlet shall be sealed with their plugs (note: this requires removal of the Aerosolv® Puncturing Unit), and the valve installed between the liquid collection drum and the carbon filter shall be turned to the OFF position. Before removing the liquid collection drum bung hole plug and re-installing the Aerosolv® Puncturing Unit, the plug sealing the carbon filter outlet bung hole shall first be removed and the valve between the liquid collection drum and carbon filter shall be turned to the ON position.
  17. Limitation to 55-Gallon Liquid Collection Drums. The certified technology shall only be used with a 55-gallon drum which meets applicable DOT standards (for transportation of hazardous materials) for the liquids to be collected. The user shall determine the applicable DOT standards for the 55-gallon drum to be used, and document the method used for achieving compliance with these standards. The user shall only use a 55-gallon liquid collection drum for use with the Aerosolv® System that is clean and in good condition, (e.g. is free of any materials or residues that would be incompatible with waste materials drained from the aerosol cans.) Under DOT regulations, collected flammable liquids with boiling point temperatures less than 95 degrees Fahrenheit are designated as Class 3 materials and must meet Packing Group I requirements, including hydrostatic pressure test performance requirements under Section 178.605 of the Code of Federal Regulations, Part 49.
  18. Usable capacity of the 55-Gallon Liquid Collection Drum. The users shall operate the certified technology with the 55-gallon liquid collection drum containing not more than 70% of its capacity, i.e., the drum shall have a minimum of 17 gallons (10 inches) of headspace. A ruler constructed of non-sparking material (not plastic) shall be used to measure the fullness.
  19. Management of Collected Residuals. The user shall classify and manage the residuals from the treatment process in accordance with all applicable federal, state, and local hazardous waste management requirements.
  20. Compliance with Applicable Federal, State, Local Regulations. The user shall comply with all applicable federal, state, and local regulatory requirements, including any permit and conditions required by the applicable local air pollution control district or air quality management district.
  21. Recycling of Scrap Metal. The user shall recycle the scrap metal generated from the treated aerosol cans. Recycling of the scrap metal generated from the treated aerosol cans shall be done in accordance with all applicable federal, state, and local waste recycling requirements. In California, the empty aerosol cans must meet the definition of scrap metal in title 22, CCR, section 66260.10 and the requirements of title 22, CCR, section 66261.7(b). If the scrap metal is disposed, instead of recycled, the conditional exemption from California permitting requirements will not apply.
  22. Revisions to Instruction Manual. Katec shall revise the Aerosolv7 6000 Instruction Manual to include conditions specified in this certification decision. Katec shall submit the amended Instruction Manual to DTSC for review and written approval. The revisions shall include a statement that DTSC has not reviewed or approved the waste segregation and consolidation provisions and that they are not part of the certification.
  23. Use of the Instruction Manual. The user of the certified technology shall follow operation and safety procedures described in the Aerosolv® 6000 Instruction Manual. A copy of the Instruction Manual shall include the conditions specified in this certification, and shall be maintained on-site and available for inspection.
  24. Continuous Quality Control/Quality Assurance and Monitoring by DTSC. By accepting this certification the applicant agrees, for the duration of the certification, that any changes to the Aerosolv® System, inst
 
 
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