ECAR
Fact Sheet for Missouri
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
Antifreeze is usually made of ethylene
glycol, corrosion inhibitors and foam controllers. Ethylene glycol
is toxic if ingested. It is particularly dangerous because animals and children are
attracted to its sweet flavor. If they drink the ethylene glycol
it may cause coma or death. Some antifreeze is made of propylene glycol. This material is less hazardous
to humans and animals than ethylene glycol.
The used antifreeze from a vehicle
can hold contaminants that it has picked up from the vehicle engine.
For example, used antifreeze may contain lead because the antifreeze has dissolved some of
the lead solder in the radiator.
The
Missouri Department of Natural Resources 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 the Department's Vehicle Salvage Compliance Guide under Other
Relevant Resources.
Regulations
Waste Classification. Waste antifreeze is not a listed hazardous waste under
the federal hazardous waste regulations. However, it may be
a hazardous waste depending
on the contaminants it has picked up. The test used to find out
if used antifreeze is a hazardous waste is called the Toxicity Characteristic
Leaching Procedure (TCLP).
Recent studies have shown that antifreeze
from cars and trucks manufactured after 1995 is not hazardous waste.
This is primarily because less lead is used in radiator construction. Used antifreeze
is more likely to be hazardous if it was used in heavy equipment such as bulldozers
and buses.
This means that antifreeze from late-model
cars and trucks that has not been mixed with other antifreeze or
with other hazardous wastes does not need to be tested. In this
case, you may assume that it is not hazardous and need not test
it. However,
used antifreeze from heavy equipment
or industrial sources will need to be tested to
see if it is hazardous waste unless
you have some other way of knowing that it is or is not hazardous.
If you wish, you can assume the antifreeze from your heavy equipment
is hazardous without testing it. You would then need to dispose
of it as hazardous waste.
If
your used antifreeze is determined 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 “WASTE ANTIFREEZE - HAZARDOUS WASTE.”
- Keep
storage containers closed to prevent evaporation and spills.
- Use
only permitted waste transporters that have obtained an EPA
identification number to transport drums of antifreeze off site.
- Keep
a copy of the test results and manifests for off-site disposal
in your files.
- Manage
the residue or filter cartridge as a hazardous waste.
Recycling. The Department strongly encourages antifreeze
recycling. If you want to recycle your hazardous waste antifreeze
on-site you must notify Department. If you recycle 2,200 lbs. or more in
a month, you need a resource recovery certification. If you recycle
antifreeze only from late-model cars and trucks, you do not need
a resource recovery certification.
Your recycling unit will create waste
such as distillation residues or used filters. You must determine
if these wastes are hazardous before disposal. If the residue is
nonhazardous, it can be sent to the landfill with your regular trash.
However, liquids cannot go to the landfill.
There may be businesses that will
bring equipment to your facility and recycle your antifreeze on-site. Again, if the
antifreeze is from late model cars and trucks, these companies do not need resource recovery
certification. If it is from heavy equipment or older cars, these companies will
need resource recovery certification to recycle your antifreeze.
Off-site Recycling or Disposal. There
are companies that pick up used antifreeze for off-site recycling
or disposal. If your used antifreeze is a hazardous waste, the transporter must have a Missouri
license to transport hazardous waste and the waste must have a hazardous waste manifest
with it. Make sure the facility you send it to has a resource recovery
certification or a hazardous waste treatment, storage and disposal permit.
Discharge to wastewater treatment
plant pouring it down the drain). If the drains at your facility go
to a wastewater treatment plant (not a septic system), you may be
able to pour antifreeze down the drain IF you have permission
from the plant. Pouring wastes down the drain is called a discharge.
Some plants will not allow discharges of used antifreeze. Large
quantities can harm the treatment plant. The wastewater treatment
plant may not be able to remove all the contaminants from the used
antifreeze. The contaminants then enter lakes, streams and rivers.
A
list of permitted recyclers and transporters in Missouri are listed
under “Other Relevant Resources.”
Spills. Notification of hazardous substance releases must
be made to the Department hot line at (573) 634-2436, or the National Response
Center at (800) 424-8802, at the earliest practical moment upon
discovery. The following information must be provided:
- Substances
involved.
- Whether
the substance is an extremely hazardous substance.
- The
medium or media into which the release occurred.
- Any
known or anticipated acute or chronic health risks associated
with the release.
- Advice
regarding medical attention necessary for exposed individuals.
- Proper
precautions to take as a result of the release including evacuation.
- Amount
of substance released or in danger of being released.
- Location
of the hazardous substance emergency and directions to the site.
- Names,
addresses, and phone numbers of persons that may have information
on the substances involved.
- When
the hazardous substance emergency occurred.
- Duration
of the release.
- When
the release was discovered.
- Actions
taken to clean up the hazardous substance and to end the hazardous
substance emergency and when those actions will be taken.
Upon
request, written follow-up notifications are required for releases
of hazardous and extremely hazardous substances.
Links
to the Regulations. Use
the following links to view the regulations pertaining to used antifreeze
management.
Missouri
Hazardous Waste Regulations (Division 25) 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.
- 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.
- 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.”
- 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 as soon as practicable.
- 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 licensed transporter and that the waste has a hazardous
waste manifest with it.
- 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.
- Keep
antifreeze storage containers closed at all times.
- 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.
- Wear
eye protection, clothing that covers exposed skin and rubber
gloves when transferring antifreeze. Pour slowly and carefully
to avoid splashing.
- 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 (unless you have
permission from your wastewater treatment plant), 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
- For
more information, contact the Missouri Hazardous Waste Program at 573-751-3176.
- To report a spill or leak, call the 573-634-2436.
-
To
report an environmental incident or complaint, contact the nearest
regional office.
Related
ECAR fact sheets
- Hazardous Wastes
Other
Related Resources
- MoDNR Antifreeze webpage
- Pollution Prevention During Vehicle Salvage
- Missouri Antifreeze Waste Management
Guide
- Missouri Hazardous Waste Transporters
- Missouri Hazardous
Waste Treatment, Storage and Disposal Facilities
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