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:
- 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.
- 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.
- 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 "Used Antifreeze,"
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 NDEP.
- 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.
- 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
- 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.
- 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.
- To
report an environmental incident or complaint, contact the NDEP
offices.
Related
ECAR Fact Sheets
- Hazardous Wastes
Other
Related Resources
- Nevada Small Business Development
Center – Used Antifreeze Management Fact Sheet
- Nevada – Antifreeze Recycling Facilities
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