Management Requirements for Handling Waste Antifreeze

Do you want to be in compliance, protect the environment, and avoid violations regarding the handling and disposal of waste antifreeze? This article provides information on how you can keep your business compliant.

What are the potential effects?

Antifreeze is a yellowish-green liquid used as freeze protection and as a heat transfer medium of motor vehicles, heavy equipment etc. Commonly referred to as coolant, it serves as a lubricant for moving parts and frequently contains ethylene glycol, a material that is toxic to humans and animals.

As a toxic product, it must be handled with care to prevent accidental poisonings as improper storage and disposal of antifreeze has resulted in fatal poisonings, contamination of underground water, etc. Furthermore, used antifreeze may contain levels of dissolved heavy metals that can also be toxic to animal life and may contaminate soils if improperly managed.

When is waste antifreeze regulated?

Waste antifreeze is antifreeze that is no longer useable for its intended purpose due to the buildup of heavy metals or loss of its original properties and is intended for storage, reclamation, or disposal.

• If the used antifreeze must be reclaimed before it can be reused as antifreeze, will be disposed of or will be used for another purpose, it is regulated as a waste in Minnesota.

• In Minnesota, used antifreeze that is reused as antifreeze without first being reclaimed is not considered a waste.

Most states have regulations for the management and disposal of waste antifreeze, regardless of whether it is a hazardous waste. In Minnesota, if you follow the three management practices listed below, you may assume that some of your waste antifreeze is not a hazardous waste. You must:

• Segregate used antifreeze that looks or smells like it contains gasoline or oil and antifreeze from vehicles that have other damage likely to cause contamination and manage as a fully regulated hazardous waste.

• Store the rest of your antifreeze in closed, clearly labeled containers, for example “Waste Antifreeze.”

• Keep records of the amount of antifreeze in both categories mentioned above and the management method- disposal or recycling, including recycling or disposal receipts. Keep the records for three years from the date of disposal or recycling.

Note: If you do not follow these management practices, you must assume all your waste antifreeze is hazardous waste, unless you evaluate it for, at a minimum, heavy metals and benzene contamination and document it as non-hazardous. Hazardous waste antifreeze must be shipped off site using a hazardous waste manifest.

Waste Antifreeze Disposal

Do not pour waste antifreeze in a stormwater drain, on the ground, into septic systems, into floor drains or mix waste antifreeze with solid waste or used oil. Immediately clean up any spills of antifreeze.

The Minnesota Pollution Control Agency (MPCA) strongly recommends recycling waste antifreeze. Non-hazardous waste antifreeze may be recycled on or off site. If you recycle on site, assume the resulting sludge or still bottoms are hazardous unless evaluated and documented as non-hazardous. Do not mix them with used oil. If you do not recycle your waste antifreeze at your facility, it may be recycled offsite by an EPA approved facility.

If you generate less than 600 gallons of waste antifreeze a year, you may have the option to discharge the waste antifreeze to the sanitary sewer. To do this, you must comply with the following:

• Notify the Publicly Owned Treatment Works (POTW)/sewage treatment plant of your intended antifreeze discharge.

• Comply with any discharge limitations, conditions and prohibitions required by the POTW.

• Record of the amount of antifreeze generated including when it was generated. Records should be kept for three years from the date it was generated.

The MPCA has a fact sheet with more details about Waste Antifreeze at: pca.state.mn.us/sites/default/ files/w-hw4-02.pdf. You can also contact the MPCA Small Business Environmental Assistance Program for confidential assistance on regulatory matters at: (651) 282-6143 or e-mail smallbizhelp.pca@state. mn.us