ECAR Fact Sheet for Vermont
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 Vermont 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 VT DEC has prepared a guidance document to help auto recyclers manage antifreeze. Much of the information is included in the fact sheet below or you can access the guidance for antifreeze under "Other Relevant Resources."

Regulations

Waste Classification. Waste antifreeze (ethylene glycol based coolant) is listed as a State regulated hazardous waste in the Vermont Hazardous Waste Management Regulations (VHWMR) and is identified by the VT08 hazardous waste code.

How you manage antifreeze will determine how it is regulated. If you reuse or recycle antifreeze on-site, your regulatory burden is lessened. If you send antifreeze off-site for disposal, your regulatory burden increases. The best way to reduce your regulatory burden would be to reuse or recycle antifreeze on-site whenever possible.

Used Antifreeze. Used antifreeze is antifreeze that has been removed from a vehicle and is to be recycled and/or treated and reused on-site. Used antifreeze does not have to be managed as a hazardous waste if it meets the below conditions:

• It has enough quality so it can be replenished through recycling and/or treatment and reused.
• Containers holding used antifreeze that is to be recycled and/or treated for reuse on-site must remain closed except when adding or removing material and must be marked with words "USED ANTIFREEZE TO BE RECYCLED."
• Any residue resulting from on-site recycling/treatment which exhibits a characteristic must be managed as a hazardous waste.
• At any given time, no more than 275 gallons of used antifreeze that is to be recycled and/or treated for reuse may be stored on-site.

Waste Antifreeze. Waste antifreeze (a Vermont-listed waste) is antifreeze that has been removed from a vehicle and is to be shipped off-site for either recycling or disposal." If it exceeds the maximum concentration limits for certain heavy metals (lead is the primary concern), benzene or other listed "toxic" materials, waste antifreeze may also be federally regulated. To determine this, you must test a sample of the waste using the Toxic Characteristic Leaching Procedure (TCLP). For a list of environmental testing laboratories, contact the Vermont Environmental Assistance Division (EAD).

Waste antifreeze is exempt from regulation as a hazardous waste provided that it does not exceed allowable concentrations of contaminants after laboratory testing, and it is destined for recycling, or permission has been obtained from the local sewer authority and Vermont's Wastewater Management Division (WWMD) to discharge the waste to a municipal wastewater treatment facility. Although it is not required, it is recommended that you obtain written permission and keep it on file until the practice is discontinued.

Determining Generator Status: For the purpose of determining the generator status of a facility, only that antifreeze which is not exempted from regulation as a hazardous waste should be included. Examples of antifreeze waste that should be counted toward your generator status include:

• Antifreeze shipped off-site destined for incineration, fuel blending, or treatment not resulting in reuse.
• Antifreeze shipped off-site that exceeds certain concentrations for lead, benzene, or perchloroethylene.

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

Storage and Labeling. Containers holding used antifreeze to be recycled and/or treated for reuse on-site must remain closed except when adding or removing material, and must be marked with words "USED ANTIFREEZE TO BE RECYCLED." At any given time, no more than 275 gallons of used antifreeze that is to be recycled and/or treated for reuse may be stored on-site.

Spills. All discharges and/or releases of hazardous waste must be immediately reported by calling the Vermont Waste Management Division at 802-241-3888 (weekdays), or the Department of Public Safety, Emergency Management Division's 24-hour hotline at 800-641-5005. This includes:

• A discharge of hazardous waste, or release of hazardous material, that when released becomes hazardous waste, which exceeds 2 gallons; or
• A discharge of hazardous waste, or release of hazardous material, that when released becomes hazardous waste, that is less than or equal to 2 gallons and poses a potential or actual threat to human health or the environment; or
• A discharge of hazardous waste, or release of hazardous material, that when released becomes hazardous waste, that equals or exceeds its corresponding reportable quantity under CERCLA as specified under 40 CFR Section 302.4.

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.

Record Keeping. Generators and transporters must manifest and keep records for the transport of antifreeze that is hazardous waste. Keep the following records on file for at least three years:

• A copy of each biennial report and manifest exception report.
• A copy of any test result, waste analysis or other determination.
• A copy of each manifest signed by the generator, transporter and designated facility

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

Vermont's 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 containers that are in good condition and properly labeled? Containers holding used antifreeze that is to be recycled and/or treated for reuse on-site must remain closed except when adding or removing material and must be marked with words "USED ANTIFREEZE TO BE RECYCLED."
2. 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 VT DEC.
3. Are you meeting storage limit requirements? At any given time, no more than 275 gallons of used antifreeze that is to be recycled and/or treated for reuse may be stored on-site.
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.

• Test antifreeze for properties such as corrosion inhibition and freeze protection before replacing and replace only when necessary.
• Substitute less toxic propylene glycol for ethylene glycol where feasible. Note: If disposed of, propylene glycol is not considered a VT08 Vermont regulated waste, however, it might be a federally regulated waste if it exceeds the maximum concentration of contaminants.
• Use "extended life" antifreeze products.
• Where the vehicle manufacturer's warranty allows, use recycled antifreeze.
• Recycle antifreeze either on-site or off-site. Regulatory burdens can be practically eliminated by recycling antifreeze on-site using either purchased equipment or contracting with a commercial mobile recycling service. There are a number of technologies available for on-site recycling of antifreeze including: filtration, distillation and ion exchange.
• Don't mix other vehicle fluid waste with used or waste antifreeze.

Contacts

1. For more information, contact the Vermont Department of Environmental Conservation, Waste Management Division at 802-241-3888.
2. To report a spill or leak, call the Vermont Division of Waste Management at 802-241-3888 (weekdays), the 24-hour spill reporting hotline
3. To report an environmental incident or complaint, call 802-241-3820, or contact the nearest regional enforcement officer.

Related ECAR Fact Sheets

1. Hazardous Wastes

Other Related Resources

1. Vermont DEC - Antifreeze Guidance Document
2. Vermont EAD - Antifreeze Guidance Document
3. Vermont EAD - Auto Salvage Yard Environmental Resource Center
4. Vermont - List of Permitted Hazardous Waste Transporters

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