ECAR Fact Sheet for Indiana
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

Under Indiana's hazardous waste rules, ethylene glycol and propylene glycol, the chemicals that make up antifreeze, are not listed hazardous wastes. However, contact with cooling system parts may cause used antifreeze to become contaminated with heavy metals, such as lead, chromium and cadmium. This contamination may make the antifreeze a hazardous waste. Or used antifreeze that is mixed with other wastes during storage may result in a mixture that is a hazardous waste.

The Indiana Department of Environmental Management (IDEM) has prepared a guidance document to help auto recyclers manage used antifreeze. Much of that information is included in the fact sheet below. You can access the link to IDEM's Compliance Manual for Auto Salvage Facilities under Other Relevant Resources.

Regulations

Waste Classification. Because antifreeze can become contaminated either through use or during storage, it may be considered a hazardous waste. Each facility is responsible for making a hazardous waste determination on its used antifreeze. This determination can be based on analytical test results of the used antifreeze, or it may be based on the knowledge of the waste and how it was generated and managed.

If your used antifreeze is considered to be a hazardous waste, you must manage it according to the hazardous waste rules. Listed below are the proper management requirements or see the ECAR Hazardous Waste Fact Sheet for more detailed information.

• Label all containers in accordance with the hazardous waste rules. Remember to clearly mark the words “HAZARDOUS WASTE” as well as the date the waste began to accumulate (or the date the container was completely filled if there is a satellite accumulation area onsite) on the used antifreeze container.
• Keep storage containers closed to prevent evaporation and spills.
• Conduct weekly inspections to ensure that the containers are in good condition. Look for leaks and for deterioration caused by corrosion or other factors. If a container leaks, put the hazardous waste or the leaking drum in another container.
• Keep monthly records of the amount of used antifreeze that is accumulated.
• Manifest drums of used antifreeze to a TSD facility .
• Use only permitted waste transporters that have obtained an EPA identification number to transport drums of antifreeze off site.

If your determine your used antifreeze is not a hazardous waste, you must:

• Never put antifreeze into the environment (i.e. onto the ground or into streams).
• Never pour antifreeze into any drains if a facility is on city water, unless the local wastewater treatment plant has been contacted in order to make sure it can handle such a discharge.
• Not discharge antifreeze to a septic system if doing so will result in the antifreeze entering and causing harm to the waters of the state of Indiana. Note that, if a facility's used antifreeze is determined to be a hazardous waste, it must not discharge it to a septic system or to the environment.
• If a facility recycles antifreeze on-site, a hazardous waste determination must be made on the filters and sludge, or they can be treated as hazardous wastes. Because the contaminants are concentrated in the filter and/or sludge, it is likely that these may be hazardous wastes.

Recycling. Used antifreeze can be recycled, but there are things to keep in mind. You may recycle your antifreeze on-site or off-site. Remember that if you recycle your antifreeze on-site, the fi lters and sludge that are generated during the recycling process may be hazardous wastes. If recycling on-site, a hazardous waste determination must be made and the waste must be managed accordingly. If this service is contracted to an outside company that recycles used antifreeze off-site, that company will be responsible for the hazardous waste generated during the recycling process.

A list of antifreeze recycling companies is included in IDEM's manual for auto salvage yards. See the link under Other Relevant Resources.

Spills. Under IDEM's Spill Rule, a spill is defined as a release of more than one pint or one pound of an objectionable substance (such as antifreeze) that could threaten to enter the ground water or surface water of the State of Indiana. Spills that occur on your property must be immediately cleaned up and properly disposed.

Not all spills are reportable. As a general rule, all spills should be reported if they:

• Create a risk to public health from fire or explosion;
• Are not contained within a building;
• Come in contact with soil or water; or
• Leave the property, or threaten to enter the waters of Indiana (including ground water).

If you determine that the spill must be reported, do so by calling IDEM's Environmental Emergency Hotline as soon as possible, but no later than two hours after the incident, by calling 317/233-7745 or toll free at 888/233-7745.

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

Indiana Hazardous Waste Resources

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 IDEM within 2 hours.
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.

Contacts

1. For more information, contact the Indiana Department of Environmental Management (IDEM) at 800-451-6027 or 317-232-8603.
2. Report spills and environmental emergencies immediately to IDEM by telephone at 1-888-233-7745.
3. Submit a pollution complaint online through the IDEM Pollution Complaints Clearinghouse.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. Indiana Auto Salvage Program Home
2. Indiana Auto Salvage Compliance Manual
3. IDEM Fact Sheet - Classification of Used Antifreeze

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