ECAR Fact Sheet for Wisconsin
Antifreeze

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.

What You Need to Know

Used antifreeze, through contact with a car's cooling system, often contains

heavy metals such as lead, cadmium, and chromium in high enough levels to make it a regulated hazardous waste. If not properly managed and stored, these pollutants can seep into soil and ground water harming people and the environment.

But in order to encourage recycling, the State of Wisconsin will give you a break and exempt you from the burden of handling it according to the usual hazardous waste rules if you manage it properly. This fact sheet will tell you:

• How to handle antifreeze to qualify for the exemption.
• What you need to do if you do not qualify in order to manage antifreeze in compliance with hazardous waste rules.

The Wisconsin Department of Natural Resources (DNR) has prepared a comprehensive guidance document on handling used antifreeze. Much of the information contained in the document is included in the fact sheet below. To view the DNR fact sheet, click on the link below under “Other Relevant Resources.”

Regulations

Antifreeze Recycling. Used antifreeze recycling methods involve two steps:

• Removing contaminants either by filtration, distillation, reverse osmosis, or ion exchange, and
• Restoring critical antifreeze properties with additives. Additives typically contain chemicals that raise and stabilize pH, inhibit rust and corrosion, reduce water scaling, and slow the breakdown of ethylene or propylene glycol.

DNR strongly encourages the recycling of used antifreeze (which is sometimes called "used engine coolant" or "used ethylene or propylene glycol"). Antifreeze becomes a waste if the original user or generator can no longer use it as antifreeze or coolant.

If it is recycled, it is considered "Wisconsin specific universal waste," which is easier and less expensive to manage.

Under the universal waste rules, you are considered a handler if you:

• Generate used antifreeze or:
• An owner or operator of a facility that receives used antifreeze from other handlers, accumulates the antifreeze, and sends the antifreeze to

another handler or to a destination facility.

There are two types of universal waste handlers:

• A "Small Quantity Handler" accumulates less than a combined total of 5,000 kilograms (approximately 1,250 gallons) of universal wastes on-site at any one time.
• A "Large Quantity Handler" accumulates 5,000 kilograms (combined total) or more universal wastes on-site at any time.

The following are the requirements that apply to both types of handlers.

Storage. Containers and tanks used by handlers to accumulate used antifreeze on-site should meet all of the following requirements:

• Be structurally sound and chemically compatible with the antifreeze;
• Remain closed and sealed at all times except when antifreeze is being added or removed;
• Show no evidence of leakage, spillage, or damage;
• Be clearly labeled or marked: "Used Antifreeze."

You SHOULD NOT MIX used antifreeze with solid or hazardous waste or other materials such as solvents or oil. Mixing the used antifreeze with other

substances may inhibit its ability to be recycled and may cause it to become hazardous waste.

Monitoring Used Antifreeze Quantities. Handlers may accumulate used antifreeze for one year from the date the used antifreeze is generated or received from another handler. Handlers may only accumulate used antifreeze for longer than one year from the date the waste is generated or received from another handler if such activity is solely for the purpose of accumulating such quantities as is necessary to facilitate proper recovery.

Handlers should demonstrate the length of time the used antifreeze has accumulated, starting from the date the antifreeze became waste or was received.

The handler may demonstrate length of time by:

• Marking or labeling containers with the accumulation start date, or
• Maintaining an inventory system on-site that identifies the earliest date antifreeze was added to a container or was received from off-site.

Employee Training. The handler should ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures.

Respond to Releases. Handlers should immediately contain and clean up all releases of antifreeze. Any residues resulting from the cleanup of antifreeze spills or leaks that exhibit a characteristic of hazardous waste should be managed according to the applicable requirements of chapters. NR 600 to 685, Wis. Adm. Code. Handlers are required to report spills of hazardous substances to the Wisconsin Division of Emergency Management at 1-800-943-0003.

Large Quantity Handlers should also meet all of the following additional requirements:

Notification.Large quantity handlers should notify DNR prior to accumulating used antifreeze, unless they have previously notified the DNR and EPA of their hazardous waste activity and received an EPA identification number. The notification form can be found under “Links to the Regulations and Forms.”

Record Keeping.Large quantity handlers should keep records for three (3) years on each shipment of universal waste received or sent. These records should include the date of each shipment, the quantities of each shipment, and the name and address of the handler or facility from which used antifreeze was received or shipped to.

Antifreeze Disposal

Used antifreeze that is not recycled and therefore, disposed of, must be handled in one of two ways:

1. Have a sample of the used antifreeze analyzed by a laboratory to find out if it is hazardous. If it is non-hazardous, it can be shipped off-site for disposal by a licensed hauler. If it is hazardous, then special hazardous waste rules apply.
2. Assume that the antifreeze is hazardous and manage it as such. This approach avoids laboratory testing costs.

See the ECAR Hazardous Waste fact sheet for details about storing, handling, and shipping of hazardous wastes.

Auto Recyclers in Wisconsin should be aware of the following regulations:

• It is illegal to discharge any hazardous waste including used antifreeze into a sanitary sewer. If you want to discharge used antifreeze, you must have data showing it's not hazardous and you must have permission from the treatment plant.
• It is always illegal to dump used antifreeze into a storm sewer or on the ground. Illegal dumping is harmful to lakes and streams, and may harm people, pets or wildlife.
• Discharging it into a septic tank and soil absorption field is illegal and will cause

groundwater pollution. It could also cause the septic system to fail.

Links to the Regulations and Forms. Use the following links to view the regulations pertaining to used antifreeze management.

Wisconsin Hazardous Waste Regulations (NR 590.01-690.81)

Wisconsin Universal Waste Regulations (NR 690)

EPA Notification Form

Federal EPA Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your antifreeze storage areas and management procedures.

1. Is used antifreeze stored in drums, tanks or other containers that are in good condition? Open containers, and rusting or leaking containers cannot be used for antifreeze storage.
2. Are antifreeze storage containers and tanks properly labeled? All waste antifreeze should be labeled "Waste Antifreeze Only," and antifreeze that can be recycled or reused, should be marked "Usable Antifreeze Only."
3. Is the area around the used antifreeze storage containers free of releases? Releases must be stopped; the released material cleaned up and managed properly and reported to the Department of Ecology.
4. Is used antifreeze transported to a recovery facility by a certified transporter? Check your records and verify that all shipments of used antifreeze were removed from your property by a state certified transporter.
5. Is oil, solvent or other materials mixed with used antifreeze? Verify that there are separate, clearly labeled containers for each type of material, and that used antifreeze is not mixed with used oil, solvents and other materials.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don’t explain how to do it. That’s where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there. The following BMPs are recommended for used antifreeze storage areas and management procedures.

• Use separate equipment for the collection of used antifreeze (funnels, pads, storage containers).
• Drain antifreeze from radiators and heater cores as soon as possible.
• Keep waste antifreeze free from cross-contamination with other wastes, including used oil, fuels, degreasers or radiator flush chemicals.
• Determine if the antifreeze is waste fluid or reusable and can be recycled.
• Recycle by reuse, distillation, filtration or ion exchange. Recycling can be done on-site or off-site by an antifreeze recycling service.
• Consider keeping antifreeze in two separate, closed containers: one for antifreeze that cannot be reused marked "Waste Antifreeze," and one marked "Usable Antifreeze."
• Do not dispose of antifreeze down storm drains, in septic tanks, dry wells or on bare ground.
• Keep any records relating to used antifreeze for at least 3 years. This includes receipts for used antifreeze shipments and any laboratory results.

1. For more information, contact Wisconsin's DNR Auto Salvage Sector Resource Specialist at 715-831-3263, or contact the WDNR Regional Office in your area. For northern Wisconsin, call 715-635-2101 or 715-365-8900; West Central Wisconsin, call 715-839-3700; Northeast Wisconsin, call 920-492-5800; Southeast Wisconsin, call 414-263-8500; and, for South Central Wisconsin, call 608-275-3266.
2. All spills should be immediately reported using Wisconsin's 24-hour toll free hotline at 800-943-0003. If you discover a discharge through analysis of soil or water, use the Hazardous Substance Release Fax Notification Form.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. Wisconsin Recycling Markets Directory
2. DNR Fact Sheet - Managing Used Antifreeze

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