ECAR Fact Sheet for New Hampshire
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 New Hampshire Department of Environmental Services (DES) 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 DES's "Waste Antifreeze: Management Requirements for Handlers and Transporters," under Other Relevant Resources.

Regulations

Waste Classification. Waste antifreeze may be managed under New Hampshire's Universal Waste Rule. Universal wastes are wastes that meet the definition of hazardous waste in the New Hampshire hazardous waste rules, but which during accumulation and transport pose a relatively low risk compared to other hazardous wastes. DES has determined that antifreeze meets the universal waste criteria.

Generator Status. If waste antifreeze is managed under the universal waste rule, it does not need to be included in the calculation of a hazardous waste generator's status. Universal wastes, when recycled, are also not subject to the state's generator fee.

Universal Waste Consolidation. You may collect waste antifreeze from other sites or generators without a permit, provided the facility meets the handler requirements covered in the Universal Waste Rule, and complies with other applicable federal, state, and local regulatory requirements.

Recycling/Disposal Options and Prohibitions You do not need a permit if you recycle antifreeze on-site at your facility. You may purchase an antifreeze distillation or filtration unit and recycle your own antifreeze on-site, hire a contractor to come in with a mobile recycling unit, or ship the antifreeze to a recycling facility. Waste antifreeze may not be disposed of by throwing it in the trash or pouring it down the drain.

Waste Antifreeze Mixtures. Waste antifreeze should not be mixed with used oil or other hazardous wastes, such as gasoline or solvents. Waste antifreeze mixed with any other material may lose its ability to be recycled and may be subject to the full requirements of the state's hazardous waste requirements. In order to avoid contamination of antifreeze with other wastes, do not use collection equipment and storage containers that have been previously used to collect other hazardous wastes or materials, unless the equipment has been decontaminated. This includes collection funnels, transfer pans or buckets, drums, and tanks.

Filters and Sludges. Any filters or sludges generated from the antifreeze recycling process must be evaluated as to whether they are hazardous wastes and managed accordingly. A recycling contractor who removes a spent antifreeze filter and sludges from a recycling unit at his or her own facility becomes the generator of these wastes. If the contractor brings a mobile recycling unit to your facility and removes a filter and sludges from the recycling unit on-site, then one of the following options must be chosen:

• The recycling contractor becomes the generator of the spent filter and sludges and transports them back to his or her site where he or she will perform a hazardous waste determination.
• The contractor may leave the filter and sludges with the waste antifreeze generator who then becomes the generator of the spent filter and sludges.

Prior arrangements should be made between the waste antifreeze generator and the contractor as to which of these options will be chosen. In either case, these wastes must be managed in accordance with the state's hazardous waste rules.

Requirements for Handlers. A waste antifreeze "handler" means:

• A generator of universal waste antifreeze; or
• An owner or operator of a facility that receives universal waste antifreeze from other handlers, accumulates the antifreeze, and sends the antifreeze to another handler or to a destination facility.

Handlers of universal waste antifreeze must either meet the following standards or comply with the generator and/or facility requirements of the state's hazardous waste rules.

Release Prevention. You must manage waste antifreeze in a way that prevents releases of antifreeze to the environment.

Quantity Limits by Generator Status.

• A Small Quantity Handler may accumulate no more than a combined total of 5,000 kilograms (11,000 pounds) of universal wastes on-site at any one time. 5,000 kilograms of antifreeze is equivalent to approximately 1,250 gallons.
• A Large Quantity Handler may accumulate greater than or equal to 5,000 kilograms, but less than 20,000 kilograms, combined total of universal wastes on-site at any time.
• A Very Large Quantity Handler may accumulate greater than or equal to 20,000 kilograms, combined total of universal wastes on-site at any time.

Storage and Labeling. Accumulate waste antifreeze in containers or tanks that are structurally sound, compatible with the antifreeze, and are closed and sealed at all times except when antifreeze is being added to or removed from the container. The containers must not show evidence of leakage, spillage, or damage. Containers stored outside shall be covered to prevent precipitation from coming in contact with the waste.

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."

Accumulation Time Limits. Accumulate waste antifreeze for no longer than one year from the date the waste antifreeze is generated or received from another handler. Demonstrate the length of time that the waste antifreeze has been accumulated starting from the date the antifreeze became waste or was received. You may make this demonstration by:

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

Training. Ensure that all employees who handle or have responsibility for managing waste antifreeze are thoroughly familiar with the handling and emergency procedures appropriate to antifreeze.

Response to Releases. Immediately contain and clean up all releases of antifreeze. Manage any residues resulting from the clean up of antifreeze spills or leaks that exhibit a characteristic of hazardous waste, in accordance with the state's hazardous waste rules. The handler is considered the generator of the residues and other clean-up waste and must meet state requirements.

Any releases that pose a threat to human health or the environment must be reported immediately to DES at 603-271-3899, or if after-hours or the weekend, contact the New Hampshire Department of Safety Hazmat Unit at 800-346-4009, 24 hours/day, and to the municipality in which the release occurred.

Off-Site Shipments. Handlers are prohibited from sending or taking universal waste antifreeze to a place other than another universal waste handler, an authorized antifreeze recycling facility, or an authorized hazardous waste facility.

Prior to sending a shipment of waste antifreeze to another handler or destination facility, the originating handler shall ensure that the receiving handler agrees to receive the shipment. Shipments must meet all applicable U.S. Department of Transportation regulations.

If a waste antifreeze shipment is rejected by an intermediate handler or destination facility, arrangements must be made by the originating handler to receive the waste antifreeze back when notified that the shipment has been rejected, or send the waste antifreeze shipment to an alternate facility.

Exports. A handler of waste antifreeze who sends the antifreeze to a foreign destination must comply with the requirements for international shipments as set forth in the state's Universal Waste Rule.

Additional Requirements for Large Quantity Handlers. A handler who plans to accumulate 5,000 kilograms or more of combined universal wastes must comply with additional large quantity handler requirements. These include notifying DES prior to the start of this activity and obtaining an EPA Identification Number, if one has not already been obtained. Records must be kept for three years on each shipment of waste received or sent. These records must include the date of each shipment, the quantities of each shipment, and the name and address of the handler or facility from which waste antifreeze was received or shipped to.

Additional Requirements for Very Large Quantity Handlers. A handler who plans to accumulate 20,000 kilograms or more of combined universal wastes must comply with the state's very large quantity handler requirements. You must:

1. Submit a notification form for each on-site location where universal waste is accumulated.
2. Ensure universal waste is not stored within a 100-year floodplain.
3. Complete and document weekly inspections of all universal waste storage areas.
4. Establish and post contingency plans and emergency procedures and provide emergency response equipment.
5. Post emergency response information at each universal waste storage area and provide access security measures to universal waste storage areas.
6. Provide closure plans and sufficient financial assurance for closure.

Requirements for Transporters. Transporters are not required to obtain a New Hampshire hazardous waste transporter registration or use a hazardous waste manifest for universal waste antifreeze, but must meet all applicable US DOT regulations. Transporters are prohibited from sending or taking waste antifreeze to a place other than another handler, an authorized antifreeze recycling facility or an authorized hazardous waste facility.

In response to releases, transporters must immediately contain and clean up all releases of antifreeze and manage any residues resulting from the clean up of spills or leaks that exhibit a characteristic of hazardous waste in accordance with the state's hazardous waste rules. Any releases which pose a threat to human health or the environment must be reported immediately to DES at 603-271-3899, Monday through Friday, 8 am to 4 pm or to NH DOS Hazmat Unit at 800-346-4009, 24 hours/day, and to the municipality in which the release occurred.

Staging During Transportation. Transporters who remove universal waste antifreeze from their vehicles and stage it temporarily are not required to obtain a hazardous waste transfer facility permit, but are subject to US DOT regulations. Transporters who stage universal waste antifreeze for more than 10 days must also meet the universal waste handler requirements.

Exports. Transporters taking waste antifreeze to a foreign destination must comply with the requirements for international shipments as set forth in the state's Universal Waste Rule.

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

New Hampshire Universal Waste Management Requirements

New Hampshire Hazardous Waste Management Requirements

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? Accumulate waste antifreeze in containers or tanks that are structurally sound, compatible with the antifreeze, and are closed and sealed at all times except when antifreeze is being added to or removed from the container. The containers must not show evidence of leakage, spillage, or damage. Containers stored outside shall be covered to prevent precipitation from coming in contact with the waste.
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 from another handler.
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 DES.
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.
6. Is oil, solvent or other materials mixed with used antifreeze? Waste antifreeze mixed with any other material may lose its ability to be recycled. Do not use collection equipment and storage containers that have been previously used to collect other hazardous wastes or materials, unless the equipment has been decontaminated.
7. Are filter and sludges being managed properly? Any filters or sludges generated from the antifreeze recycling process must be evaluated as to whether they are hazardous wastes and managed accordingly.

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 one year.

Contacts

1. For more information, contact the New Hampshire DES Waste Management Division at
   603-271-2900.
2. To report a spill or leak during business hours, call the DES at 603-271-3899. If after hours or the weekend, call the New Hampshire State Police Hazardous Material Response at 800-346-4009 (in-state), or 603-271-3636 (out-of-state).
3. To report an environmental incident or complaint, contact the nearest regional office or link to the DES Public Information Center.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. New Hampshire - Waste Antifreeze Management Guidance

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