The following questions and guidance are taken from the |
Consolidated Screening Checklist For Automotive Repair Facilities.
Is used antifreeze properly contained, segregated, and labeled?
Yes--All three of the following criteria are met:
- Labeled--Labels or color coating indicate
that the container contains only antifreeze. In contrast to
used oil, there are no set labels for antifreeze. To be
considered properly labeled, the drum/container/tank should
simply have the words "used antifreeze" or "waste antifreeze,
or "antifreeze only", or something similar that distinguishes
antifreeze storage from oil and solvent storage. Words can be
spray painted, stenciled, crayoned, or more formally labeled.
- Segregated--Used antifreeze is in its own
container and not mixed with other liquids.
- Contained--Containers are closed (lids are
on and caps are screwed on tight, except when actually adding
or removing liquid).
No--Any of the above are not done.
Does the facility generate any antifreeze that is a hazardous waste
(>5 ppm lead)?
A facility generates hazardous antifreeze if it has characterized
antifreeze as hazardous waste. Antifreeze would be considered
hazardous if it is mixed with a hazardous waste such as solvent or
gasoline. Antifreeze could also be hazardous if it comes from an old
car where the antifreeze has been sitting for years and has picked up
enough metals to be characterized as hazardous for metals content, or
if the pH > 12.5.
Yes--Facility mixes hazardous solvent or gasoline with
waste antifreeze, has tested its antifreeze and determined it is
hazardous, or knows from process knowledge (e.g., it only works on old
beat up cars that may leave lead or other metals in antifreeze) that
its antifreeze is hazardous.
No--Facility has determined its antifreeze is not
hazardous by testing the antifreeze or process knowledge (facility understands the
potentially hazardous constituents in antifreeze and has determined that the antifreeze it
generates is not hazardous, or has explained its process to the state EPA and have been
told that their antifreeze is not a hazardous waste).
Don't know--Facility has not made a determination
whether its used antifreeze is a hazardous waste, but simply manages
it as it believes is the right way to do so.
If yes, is it recycled onsite in a closed loop system?
Yes--Antifreeze is recycled by a recycling machine that
connects directly to the car's radiator, recycles the antifreeze, and
puts it right back into the same car that it came from. A similar
system that connects to used antifreeze storage drums is not
considered a closed loop system.
No--Used antifreeze is not recycled in a closed loop system.
If no, is it counted toward facility generator status?
This question is just a reminder from the 2nd question on the
checklist that any antifreeze that is a hazardous waste needs to be
considered as part of the 100 kg/220 pounds per month limit for
Conditionally Exempt Small Quantity Generators.
Yes--Hazardous waste antifreeze that is not recycled in
a closed loop system is included in the total from question 2 of the
No--Hazardous waste antifreeze is not included.
If used antifreeze is not recycled onsite, how is it disposed?
Recycled offsite--The antifreeze is recycled offsite and
the facility has the EPA identification number of the recycler
(should be on shipping papers.)
Mixed with other fluids--Antifreeze is mixed with used
oil, solvents, or other fluid.
Landfill--Antifreeze is disposed at the landfill. Many
landfills have a tank designated for used antifreeze. For this
question, "landfill" does not include antifreeze that is dumped in the
Other--Method of disposal is not listed.