INTRODUCTION

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.

Waste antifreeze may be managed under the New Hampshire Universal Waste Rule, which became effective October 13, 2001, and is further described in this fact sheet. DES believes that recycling is the preferred option for managing waste antifreeze and that this rule will promote the recycling and proper management of waste antifreeze.

Types of Antifreeze Recycling

Recycling methods include filtration, distillation, and ion exchange. Distillation and ion exchange restore the antifreeze to a high level of purity. Some major vehicle manufacturers allow antifreeze recycled by these methods to be used in vehicles under warranty. Check with vehicle manufacturers for more information. Simple filtration processes are not designed to remove dissolved contaminants. However, use of very fine filters or a series of filters, followed by the addition of chemicals to refortify the antifreeze, such as rust and corrosion inhibitors, acid neutralizers, anti-clogging and anti-foaming agents, and pH buffers, can result in a product that meets the American Society of Testing and Materials (ASTM) standards.

Universal Waste

"Universal wastes" are wastes that meet the definition of hazardous waste in the N.H. Hazardous Waste Rules, but which during accumulation and transport pose a relatively low risk compared to other hazardous wastes. Wastes that DES has determined meet universal waste criteria include antifreeze, mercury-containing lamps and devices, cathode ray tubes, certain types of batteries, and recalled or suspended hazardous waste pesticides regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

Generator Status

If waste antifreeze and other universal wastes are managed in accordance with this rule, such wastes do not need to be included in the calculation of a hazardous waste generator’s status (see Env-Wm 503 of the N.H. Hazardous Waste Rules). Universal wastes, when recycled, are also not subject to the generator fee at Env-Wm 512.02.

Universal Waste Consolidation

A facility 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 Env-Wm 1101-1114 and complies with other applicable federal, state, and local regulatory requirements.

Recycling/Disposal Options and Prohibitions

On-site recycling at a generator’s facility is not subject to permitting requirements. Generators may purchase an antifreeze distillation or filtration unit and recycle their 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 N.H. Hazardous Waste Rules. 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. Refer to the N.H.Hazardous Waste Rules, Env-Wm 502, for hazardous waste determination requirements.

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 a waste antifreeze generator’s site and removes a filter and sludges from the recycling unit at the generator’s site, then one of the following alternatives must be chosen:

(a) 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.

(b) 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 N.H. Hazardous Waste Rules.

REQUIREMENTS FOR HANDLERS

A waste antifreeze "handler" means: (1) a generator of universal waste antifreeze; or (2) 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 N.H.Hazardous Waste Rules.

1. Release Prevention

Manage waste antifreeze in a way that prevents releases of antifreeze to the environment.

2. Quantity Limit

1. 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.

2. 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.

3. 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.

3. Containers and Tanks

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.

4. Labeling

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."

5. 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. The handler may make this demonstration by:

(1) Marking or labeling containers with the starting accumulation date; or

(2) Maintaining an inventory system on-site that identifies the earliest date that antifreeze was added to a container or was received from off-site.

6. 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.

7. 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 N.H. Hazardous Waste Rule. The handler is considered the generator of the residues and other clean-up waste and must meet the requirements of Env-Wm 500.

Any releases that 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 New Hampshire Department of Safety Hazmat Unit at 1-800-346-4009, 24 hours/day and to the municipality in which the release occurred.

8. 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.

9. 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 Env-Wm 1102.08 of the 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 of Env-Wm 1104. These include:

1. Notifying DES prior to the start of this activity and obtaining an EPA Identification Number, if one has not already been obtained.
2. Keeping records 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 very large quantity handler requirements of Env-Wm 1105. These include:

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.

Response to Releases

1. Transporters must immediately contain and clean up all releases of antifreeze.
2. Any residues resulting from the clean up of spills or leaks that exhibit a characteristic of hazardous waste must be managed in accordance with the N.H. Hazardous Waste Rules. The transporter is considered the generator of the residues and other clean-up waste and must meet the requirements of Env-Wm 500.

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 1-800-346-4009, 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 Env-Wm 1106.06 of the Universal Waste Rule.

FOR MORE INFORMATION

Questions on this policy should be directed to DES’s Pollution Prevention and Education Section at (603)-271-2956 or the Hazardous Waste Compliance Section at (603) 271-2942. A list of antifreeze recycling facilities, copies of other fact sheets, and the N.H. Hazardous Waste Rules or Solid Waste Rules are available from DES’s Public Information and Permitting Office at (603)-271-2975 (TDD Access: Relay NH 1-800-735-2964). Copies of DES fact sheets, a list of recyclers and rules are also available on DES’s web site at www.state.nh.us/des.

Information on US DOT and NH DOS regulations can be obtained from the N.H. Department of Safety, Hazmat Unit at (603) 271-3349.

Disclaimer: Information contained in this fact sheet is current as of March 7, 2002. Policy and regulatory changes occurring after this date may affect part or all of this information. For questions on the status of this information, contact DES at 603-271-2942.