ECAR Fact Sheet for Michigan
Used 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 may or may not be a hazardous waste depending if it has been contaminated.

Determine if antifreeze removed from radiators or hoses is reusable or a waste.

• If it is a usable product without needing any recycling, keep it in a closed, labeled container and reuse it.
• If it is a waste or needs to be recycled before it can be reused, this fact sheet will tell you how to handle used antifreeze.

Regulations

Waste Classification. Antifreeze consists of either ethylene glycol or propylene glycol and additives mixed with water. During use, antifreeze can become contaminated with traces of fuel, metal particles, or other contaminants. Used antifreeze should never be disposed of down storm drains or surface waters. It is illegal and dangerous to discharge used antifreeze to septic systems or to the outdoors.

It is necessary to determine if used antifreeze is hazardous waste or liquid industrial waste. This can be done by either:

1. Having a sample of the used antifreeze analyzed by a laboratory to find out if it is hazardous. Used antifreeze may be hazardous waste due to having:
   • Accumulated heavy metals [e.g., lead levels may reach a TCLP concentration of 5.0 mg/L or greater(D008 waste). Spent antifreeze is likely to be hazardous waste if it was from an older vehicle that has been sitting for years and has picked up enough metals or from radiators made with lead solder.]
   • Traces of fuel [e.g., may make it flammable (D001 waste). Spent antifreeze may be hazardous waste if it has been mixed with gasoline and it has a flashpoint less than 140°F or it contains benzene TCLP concentrations of 0.5 mg/L or greater that would make it have a toxicity hazardous waste characteristic (D018).
   • Other contaminants from engine parts at regulated toxicity levels.
   • Broken down over time and had acids form [e.g., may make it a corrosive hazardous waste (D002) if the pH is less than or equal to 2.0.]
   • Being cross contaminated by other hazardous waste like overspray from brake cleaners containing listed solvents

2. Using knowledge about the waste. For example, you could assume that the antifreeze is hazardous and manage it as such. Some facilities have noted that antifreeze removed from cheaper radiators have lead levels that make it hazardous waste. This approach avoids laboratory testing costs but there may be higher disposal costs.

If it is non-hazardous, it is managed as liquid industrial waste in Michigan. It would need to be shipped off-site for disposal by a permitted and registered hauler. If it is hazardous, then the hazardous waste rules apply. Keep records of waste characterization at least 3 years. See the ECAR Hazardous Waste fact sheet for details about storing, handling, and shipping of hazardous wastes.

Storage of Used Antifreeze. Check with your recycler before mixing the different spent antifreeze chemicals together. Do NOT mix spent antifreeze that is hazardous waste with used oil or any other waste. If it is not hazardous, check with recycler or disposal company before mixing it with other wastes.

• Store in a container in good condition with no leaks or defects. The container must be compatible with the antifreeze stored in it.
• Keep the container closed at all times except when emptying or filling.
• Label the container (see below).
• Provide secondary containment of the storage area. This is recommended for all storage areas and in some situations may be required. Secondary containment is required for the storage of ethylene glycol antifreeze in aboveground containers if the facility has 440 pounds stored outside or 2200 pounds indoors of all polluting materials. See Part 5 rules for list of other regulated chemicals that would be included in this volume.
• Store in a well-ventilated area.
• Store no longer than the allowable time period. There is no time limit if the spent antifreeze is a liquid industrial waste or if it was generated by a CESQG. If the spent antifreeze is a hazardous waste, then the following time limits apply:
  • SQGs may accumulate up to 180 days. If the distance to the treatment, storage, and disposal facility is over 200 miles, then it can be accumulated up to 270 days.
  • LQGs may accumulate up to 90 days.
• Inspect the containers holding hazardous waste for signs of corrosion and leaks. Tanks have other specific requirements.
  • CESQGs have no specified inspection time schedule.
  • SQGs and LQGs must inspect containers weekly. LQGs are required to keep written inspection records for at least 3 years. It is recommended other generators keep records.
  • Regular inspections are recommended for containers holding liquid industrial waste.

Labeling. Use the following labeling for antifreeze.

• If not hazardous or generated by CESQG, label with “Spent Antifreeze” or “Used Antifreeze”
• If antifreeze is hazardous waste generated by SQG and LQG:
  • If the container is in an accumulation area, the label has to have the words .hazardous waste, the hazardous waste code, and the accumulation start date on it. That’s the date waste was first put into the container.
  • If the container is being used as a satellite container it must be labeled with the words .hazardous waste and the waste code or the common name like used antifreeze. A satellite container is one used to accumulate up to 55 gallons of hazardous waste, or one quart of acutely hazardous waste, at the point of generation. There is no limit on how long the satellite container can be kept at its location as long as it is used on a regular basis, the operator has control of the process generating the waste, and the satellite accumulation does not exceed the 55-gallon limit. Satellite containers must be kept closed except when adding or removing waste.
  • Meet US DOT labeling requirements when shipping hazardous waste off-site.
• Label reconditioned or recycled antifreeze containers with the words "Reconditioned or Recycled Antifreeze."

Spill Control. All spills must be cleaned up. Spills into water must be reported to the MDEQ. Other spills may be required to be reported depending on amounts and whether the facility is subject to certain regulations. Determine in advance of an emergency what are the facility’s reporting requirements.

Recycling and Filter Management. Operating an antifreeze recycling unit on-site:

• Does not require a permit from the Waste and Hazardous Materials Division if the antifreeze was generated at that location and if it is hazardous waste, the requirements under rule R 299.9503(1)(i) are met. However if antifreeze that is hazardous waste is brought to the site, then a permit and license are required if storing and/or recycling spent. Contact the the Waste and Hazardous Materials Division District Office for more information.
• Depending on the unit, an air permit might be needed if the equipment discharges air emissions. Contact the Air Quality Division District Office for information.

Facility must determine if the sludge and waste filters derived from the recycling process are a hazardous waste. If the waste is hazardous, then it must be managed according to Part 111 See the ECAR Hazardous Waste fact sheet for additional information. If the residue is not a hazardous waste and does not contain liquids, it may be disposed of in a licensed solid waste landfill.

Record Keeping. Waste manifests would need to accompany shipments of used antifreeze. Submit copies to DEQ as required. Keep copies at least 3 years from date of shipment. Keep waste characteriziation records at least 3 years.

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

Michigan’s Natural Resources and Environmental Protection (Act 451), Part 111 regarding Hazardous Waste Management and administrative rules

Michigan’s Natural Resources and Environmental Protection (Act 451), Part 121 regarding Liquid Industrial Waste

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? Used antifreeze storage containers that are not hazardous waste must be labeled "Used Antifreeze."
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 MDEQ.
4. Is used antifreeze transported to a recovery facility by a permitted and registered transporter? Check your records and verify that all shipments of used antifreeze were removed from your property by a registered 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).
• Label used antifreeze collection equipment and containers "Used Antifreeze."
• 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.
• Use dedicated equipment such as drain pans, funnels, and buckets to reduce the risk of contamination from other hazardous waste and label “only use with antifreeze”.
• Do not use a container that is lined with paint, resin, or other materials that could further contaminate the used antifreeze.
• Do NOT store antifreeze in old food or beverage containers for safety reasons.
• Label reconditioned or recycled antifreeze containers "Reconditioned or Recycled Antifreeze."
• Properly label waste antifreeze (see above section)
• Install an antifreeze recycling system. [Waste antifreeze recycling methods involve two steps: (1) removing contaminants either by filtration, distillation, reverse osmosis, or ion exchange and (2) 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 glycol.]
• Keep any records relating to used antifreeze for at least 3 years. This includes manifests for used antifreeze shipments and any laboratory results.
• Employ the following procedure for antifreeze spills on floors:
• Mop up the antifreeze immediately using a dedicated cloth mop. Transfer collected antifreeze to the properly labeled antifreeze waste container for recycling.
• Use rags to dry the floor. Place used rags in properly labeled waste containers and send rags to an industrial laundry. Do not saturate the rags; otherwise you will have drips on the floor as you transfer them to the waste containers.
• Use a wet mop only if necessary for final cleaning. Use mild, non-caustic detergent.

Contacts

1. For more information, contact MDEQ’s Environmental Assistance Center at 1-800-662-9278.
2. For reporting spills/releases and pollution emergencies, contact: 1-800-292-4706.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. MDEQ Used Antifreeze
2. Recycled Materials Market Directory Oils and Solvents Categor

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