ECAR Fact Sheet for Nevada
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, through contact with a car's cooling system, may contain traces of lead and benzene, making it a possible hazardous waste. If not properly managed and stored, these pollutants can seep into soil and groundwater harming people and the environment.

But in order to encourage recycling, the State of Nevada will give you a break and exempt you from the burden of handling it according to the usual hazardous waste rules if you manage it properly. This fact sheet will tell you:

• How to handle antifreeze to qualify for the exemption.
• What you need to do if you do not qualify in order to manage antifreeze in compliance with hazardous waste rules.

The Nevada Small Business Development Center 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 guidance for antifreeze under "Other Relevant Resources."

Regulations

Waste Classification. In Nevada, used antifreeze is regulated as a nonhazardous

waste if it is being recycled. If the used antifreeze is not being recycled, you are responsible for making a waste determination on the used antifreeze, and disposing of it according to the waste determination results. It may be considered a hazardous waste.

However, if used antifreeze is recycled, it doesn't need to be treated as hazardous waste. Recycling can be done on-site or off-site by an antifreeze recycling service. A list of antifreeze recyclers is listed under "Other Relevant Resources." Another option for recycling antifreeze is to contract with a mobile recycler.

If you use a mobile antifreeze recycler, they should have a "written determination" issued by the NDEP and be able to provide a copy of this determination to any business requesting it.

Used antifreeze that is not recycled and therefore, disposed of, must be handled in one of two ways:

1. Have a sample of the used antifreeze analyzed by a laboratory to find out if it is hazardous. If it is non-hazardous, it can be shipped off-site for disposal by a licensed hauler or discharged to a municipal wastewater treatment system. You must check with your local water treatment authorities and a permit may be required). If it is hazardous, then special hazardous waste rules apply.
2. Assume that the antifreeze is hazardous and manage it as such. This approach avoids laboratory testing costs.

See the ECAR Hazardous Waste fact sheet for details about storing, handling, and shipping of hazardous wastes.

Storage and Labeling. There are minimum requirements for storing used antifreeze on-site prior to recycling. While used antifreeze is being stored on-site, ensure the following:

• Used antifreeze should be stored in containers that are in good condition (not rusted or leaking).
• All containers storing used antifreeze should be labeled "Used Antifreeze." If the antifreeze is being recycled, it is not considered a hazardous waste and the containers does not need to have the words "Hazardous Waste."
• All containers storing used antifreeze must be closed at all times when waste is not being added or removed.

Spills. Clean up all spills right away. Keep spill control equipment in a central location, accessible to all employees. Spills of reportable quantities must be reported to the Nevada Division of Environmental Protection as soon as possible, but no later than the end of the first working day of the release at 888-331-NDEP (6337).

Filter Management. Waste antifreeze filters and particulate generated from recycling antifreeze also must be managed as hazardous waste or proven that they are non-hazardous through laboratory analysis. See the ECAR Hazardous Waste fact sheet for additional information.

Transporting Used Antifreeze. A generator of used antifreeze may transport, without notifying as a transporter to EPA, up to 350 gallons of used antifreeze, provided the antifreeze is transported in a vehicle owned by the business that generated the used antifreeze or a vehicle owned by an employee of that business.

The 350 gallon threshold only applies to a business transporting their own used antifreeze that was generated at their own business; anyone in the business of collecting or transporting used antifreeze from other businesses must comply with much more stringent requirements.

Record Keeping. Keep all receipts of used antifreeze shipments and filter management. The written receipts or records must include:

• Address/EPA ID# (if any) of the business generating the used antifreeze;
• Name/address/EPA ID# of the antifreeze collection center (where the antifreeze is being transported to for temporary storage) and/or the permitted antifreeze recycling facility;
• The amount of used antifreeze being transported; and
• Date/signature from the collection center or recycling facility

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

Nevada's Antifreeze Recycling Requirements (444.8801-9071)

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 "Used Antifreeze," 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 NDEP.
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.

• Secondary containment around all antifreeze storage containers is recommended, though it is not required by hazardous waste regulations. Placing a spill kit (a trash can with floor dry and a scoop) near the storage area is also recommended. Preventing a spill from entering a floor drain or contaminating soil can save a business time, bad public relations, and money in the long run.
• 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 Nevada Department of Conservation and Natural Resources (NDEP), Division of Environmental Protection, Bureau of Waste Management at 775-687-4670.
2. To report a spill or leak, call the NDEP as soon as possible, but no later than the end of the first working day of the release at 888-331-NDEP (6337). For reporting releases or suspected releases only - outside of Nevada - 1-775-687-9485. For information on reporting requirements, call the Bureau of Corrective Actions at 775-687-9368.
3. To report an environmental incident or complaint, contact the NDEP offices.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. Nevada Small Business Development Center - Used Antifreeze Management Fact Sheet
2. Nevada - Antifreeze Recycling Facilities

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