ECAR Fact Sheet for Louisiana
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

Antifreeze is used as an engine coolant and commonly consists of ethylene glycol or propylene glycol. Antifreeze breaks down over time and forms acids that corrode a vehicle's cooling system. During its use, antifreeze may become contaminated with traces of fuel, metal particles, and grit. Benzene, lead, and other hazardous constituents may cause used automotive antifreeze to be characterized as a hazardous waste.

The Louisiana Department of Environmental Quality (DEQ) has prepared a guidance document to help auto recyclers manage antifreeze. Much of the information is included in the fact sheet below. You can access the DEQ's antifreeze guidance under Other Relevant Resources.

Regulations

Waste Classification. Waste antifreeze may be managed under Louisiana's Universal Waste Rule. Antifreeze is defined as an ethylene glycol based mixture that lowers the freezing point of water and is used as an engine coolant. In order to managed under the universal waste rule, the antifreeze must be a waste as well as a hazardous waste.

Small Quantity (SQH) and Large Quantity (LQH) Handlers.

• A SQH of universal waste is a handler who does not accumulate 5,000 kilograms or more total of universal waste batteries, pesticides, thermostats, lamps, or antifreeze, calculated collectively, at any time.

• A LQH of universal waste is a handler who accumulates 5,000 kilograms or more total of universal waste batteries, pesticides, thermostats, lamps, or antifreeze, calculated collectively, at any time. This designation as a LQH of universal waste is retained through the end of the calendar year in which 5,000 kilograms or more total universal waste is accumulated.

Prohibitions. SQH's and LQH's are prohibited from disposing of antifreeze, and from diluting or treating antifreeze, except by responding to releases, or by managing the antifreeze in compliance with state regulations.

Notification Requirements. A SQH is not required to notify the DEQ of its universal waste handling activities. A LQH of universal waste must have sent written notification of universal waste management to the state's permit division, and have received an EPA Identification Number, before meeting or exceeding the 5,000 kilogram storage limit.

Antifreeze Storage Requirements. Both SQH's and LQH's of universal waste must manage universal waste antifreeze in a way that prevents releases to the environment. The universal waste antifreeze must be contained in one or more the following:

• A container that remains closed, structurally sound, and compatible with the antifreeze and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. If the container does not meet these requirements, it must be overpacked in a container that does meet the standards.

• A tank that meets the state's requirements.

• A transport vehicle or vessel that is closed, structurally sound, and compatible with the antifreeze and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.

Antifreeze storage. Antifreeze must be managed in a way that prevents releases to the environment. Antifreeze must be kept in a container, tank, or other vessel that remains closed, is structurally sound, and lacks evidence of leaks, spills, or damage that could cause leaks.

Accumulation Times. Do not store antifreeze for more than one year. You should keep records of accumulation times using one of the following methods:

• Marking either the storage area, the containers, or individual items of antifreeze with the earliest date that the antifreeze became a waste or was received;

• Maintaining an inventory system on-site that identifies the date the antifreeze became a waste or was received; or

• Using any other method which clearly demonstrates the length of time that the antifreeze has been accumulated from the date it becomes a waste or is received.

Labeling Antifreeze. Both SQH's and LQHs must clearly mark or label antifreeze as "Universal Waste - Antifreeze," "Waste Antifreeze," or "Used Antifreeze."

Employee Training. You must inform all employees who handle or have responsibility for managing antifreeze of proper handling and emergency procedures.

Response to Releases. You must immediately contain all releases and other residues of antifreeze and determine whether any material resulting from the release is a hazardous waste.

Transporting Antifreeze. Antifreeze can only be taken to another universal

waste handler, a destination facility, or other approved destinations. A SQH of universal waste is not required to keep records of shipments of universal waste. If SQH's self-transport antifreeze off-site, you must comply with the state's transporter requirements.

A LQH of universal waste must keep a record of each shipment of universal waste received at the facility. The record may take the form of a log, invoice, manifest, bill of lading, or other shipping document. The record for each shipment of universal waste received must include the following information:

• The name and address of the originating universal waste handler or foreign shipper from whom the universal waste was sent.

• The quantity of each type of universal waste received.

• The date of receipt of the shipment of universal waste.

Shipments Off-Site. A LQH of universal waste must keep a record of each shipment of universal waste sent from the handler to other facilities. The record may take the form of a log, invoice, manifest, bill of lading or other shipping document. The record for each shipment of universal waste sent must include the following information:

• The name and address of the universal waste handler, destination facility, or foreign destination to whom the universal waste was sent.

• The quantity of each type of universal waste sent.

• The date the shipment of universal waste left the facility.

Recordkeeping Requirements. A LQH of universal waste must retain records for at least three years from the date of receipt of shipments to the facility or from the facility.

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

Louisiana Universal Waste Management Requirements (Part V, Chapter 38)

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? Store antifreeze in a container that remains closed, is structurally sound, and compatible with the antifreeze and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.

2. Are you storing the antifreeze for the permitted accumulation time? Do not store antifreeze for more than one year from the date the waste antifreeze was generated or received.

3. Are antifreeze storage containers and tanks properly labeled? Clearly label or mark each container or tank of waste antifreeze with any one of the following phrases: "Universal Waste Antifreeze," or "Waste Antifreeze," or "Used Antifreeze."

4. Is the area around the used antifreeze storage containers free of releases? Releases must be immediately stopped, cleaned up and managed properly. Any releases that pose a threat to human health or the environment must be reported immediately to DEQ.

5. Is used antifreeze transported to an approved recovery facility? Ensure that all shipments of used antifreeze were taken to another universal waste handler, or an authorized antifreeze recycling or hazardous waste facility by the transporter.

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.

• Do not mix waste antifreeze with used oil or other hazardous wastes.

• Do not use collection equipment and storage containers that have been used previously to collect other hazardous wastes or materials. Store waste antifreeze in structurally sound containers.

• Clearly mark or label each container with "Universal Waste " Antifreeze," "Waste Antifreeze," or "Used Antifreeze."

• Evaluate and determine the waste status of filters and sludges.

• Manage antifreeze in a way that prevents the release of antifreeze to the environment.

• Recycling can be done on-site, by hiring a contractor to come in with a mobile recycling unit, or by shipping the antifreeze to a recycling facility.

• Do not accumulate antifreeze for more than one year.

• Ensure all employees are properly trained with handling and emergency procedure relating to antifreeze.

• Immediately contain all releases of antifreeze and report any releases that pose a threat to human health or the environment.

• Do not dispose of antifreeze in the trash or by pouring it down the drain.

• Ensure antifreeze is sent to approved recycling or other facilities.

• Keep any records relating to used antifreeze for at least three years.

Contacts

1. For more information, contact the Louisiana Department of Environmental Quality (DEQ), Office of Environmental Services at 225-219-3181.
2. To report a spill or leak, call the DEQ's 24-Hour Notification Hotline at 225-342-1234. You can access notification procedures at the DEQ's Single Point of Contact Procedures website.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. Louisiana - Universal Waste Fact Sheet
2. Louisiana Hazardous Waste Notification Form & Instructions

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