24. USED ANTIFREEZE
Used antifreeze means ethylene glycol-based coolant that has been used and, as a result of contamination, can no longer serve the purpose for which it was produced without processing.
24.1 INTRODUCTION
This chapter of the Douglas County Comprehensive Solid Waste Management Plan (DCCSWMP) outlines the regulatory framework overseeing used antifreeze, discusses the existing conditions and programs within the Regional Planning Area (RPA), establishes objectives to meet the existing and projected needs, identifies alternatives, and recommends actions for achieving the established objectives.
24.2 REGULATORY FRAMEWORK
24.2.1 Federal Requirements
The Environmental Protection Agency (EPA) has designated used antifreeze as a hazardous waste. The EPA has established regulations concerning the recycling of used antifreeze as an alternative to disposal.
24.2.2 State Requirements
The State of Washington classifies used antifreeze as a Dangerous Waste (DW) and regulates it under Chapter 173.303 WAC. Generators who recycle their used antifreeze are conditionally exempt from the dangerous waste regulations if they comply with all the requirements of WAC 173.303.522. Those generators not meeting the conditionally exempt classification must meet all the record keeping, storage, transportation and disposal requirements for a dangerous waste. If dangerous wastes are mixed with used antifreeze, the total mixture becomes a dangerous waste and is subject to the dangerous waste regulations.
The specific generator requirements for recycling used antifreeze as contained within WAC 173.303.522 are:
- must keep records for a period of five years from the date of reclamation/recycling.
- containers and tanks used to accumulate used antifreeze must be labeled "spent antifreeze".
- used antifreeze that is to be reclaimed can be accumulated on-site for any length of time, and in any amount.
- during accumulation, used antifreeze must be stored in a manner to prevent releases to the environment.
Owners or operators of facilities that receive recyclable materials from off-site and recycle these recyclable
materials without storing them before they are recycled, are subject to the requirements of WAC
173.303.120(4)(c).
24.2.3 Local Requirements
Douglas County
Any jurisdiction, agency, private corporation, individual or other entity wishing to import used antifreeze into Douglas County must conform to the Douglas County Solid Waste Importation Ordinance (DCSWIO). As specified within the ordinance, a formal Letter of Request to the Douglas County Board of Commissioners requesting that their application for solid waste importation be reviewed is required. Only after the Douglas County Board of Commissioners have received a Letter of Request will the review and approval process begin. The Douglas County Board of Commissioners will review the information contained within the Letter of Request with county staff and others. If it is determined by the Douglas County Board of Commissioners that sufficient information has been provided, that all known potential adverse impacts have been identified, assessed and mitigated, the request may be approved.
Within Douglas County no person shall deposit, discard or otherwise dispose of any used antifreeze upon any public place within the county or upon a private residence or other private property not owned by him/her, or in any waters within the county except;
- when such property is designated by the state or any of its agencies or the county for the collection of used antifreeze, and such person is authorized by the appropriate permitting authority to so use such property;
- with the prior written consent of the landowner approving of such collection upon their private property.
Additionally, within Douglas County all owners or persons in control of any private residence or other private property shall at all times maintain the premises free of any used antifreeze that pose a risk to public health and safety, the environment or create a nuisance.
24.3 EXISTING CONDITIONS
24.3.1 Education
An education program is in place to inform generators of the options available to them to properly dispose of or recycle their used antifreeze. The program has utilized resources through the media (radio, newspaper), posters, brochures and direct personal communications. Used Antifreeze Notification posters are available through the DCSWPO. Brochures have been distributed throughout the RPA announcing the location, hours of operation, phone number and point of contact for each of the used antifreeze collection centers.
24.3.2 Private Used Antifreeze Transporters
A number of private antifreeze transporters provide service to the RPA. These antifreeze transporters collect the used antifreeze from businesses for a fee. These companies have been well established within the RPA for a number of years and have established a client base primarily within the Greater East Wenatchee Area.
24.3.3 Used Antifreeze Collection Centers
Currently there are four Used Antifreeze Collection Centers (UACC) within the RPA. The four UACCs are open to the general public with established days and hours of operation. The four UACCs within the RPA are located at:
- City of Bridgeport Maintenance Shop
- City of Rock Island Community Recycling Center
- Town of Mansfield Community Recycling Center
- Town of Waterville Community Recycling Center
The general public is encouraged to bring their used antifreeze to the UACC. The used antifreeze is removed from the public container(s) and placed into Department of Transportation (DOT) approved containers. Each clear 55-gallon plastic container is labeled as "spent antifreeze". Once the used antifreeze is inspected for clarity, impurities, oils and sludges, it is drained into the plastic container and the delivery container is returned to the public for reuse. All contaminated used antifreeze is rejected. All participants disposing of used antifreeze are required to fill out and sign a certification form and pay a small handling fee.
Map 24-1. Used Antifreeze Collection Centers within the RPA
Once the 55-gallon plastic container is full, it will be properly sealed and temporarily stored at the collection center. On an as-needed basis the properly sealed containers will be serviced by the contracted antifreeze vendor. Each UACC will have two recycling options provided to it by the contracted antifreeze vendor. For a minimal transportation fee, the contracted antifreeze vendor will pick-up the full container(s), drop-off replacement container(s) and transport the used antifreeze from the collection center. The second option available is for the contracted antifreeze vendor to reclaim and recondition the used antifreeze on-site and, for an additional fee, provide it to the collection facility.
Table 24-1 Quantity of Used Antifreeze Collected within the RPA
|
1998 |
1999 |
|
155 gallons |
1310 gallons |
Source: Bill Tinney II
24.4 OBJECTIVES
24.4.1 Ensure that Used AntiFreeze is Properly Managed
With the generator being responsible for the proper management of their antifreeze, it is very important that the generator properly dispose of their used antifreeze. Failure of a generator to properly manage their used antifreeze can pose a direct threat to the public health and safety and the environment.
24.4.2 Ensure that All Facilities Receiving Used Antifreeze meet all Federal, State and Local Regulations
With both federal and state regulations specifying how used antifreeze is to be handled, managed, transported and disposed of, it is very important that the generators of this waste be properly educated. Failure of a generator to properly handle, manage, transport and dispose of their used antifreeze can result in substantial penalties, fines and corrective actions.
24.4.3 Ensure Programs Reflect Local Conditions
With the tendency of regulatory agencies to have a one-size fits all approach, it is imperative that all programs be locally supported and accepted. Because of the rural character of Douglas County and its cities and towns, all programs should reflect conditions that exist locally and not be driven by what the DOE deems as efficient or cost effective.
24.4.4 Ensure that the Public has an Opportunity to Recycle
With restrictions placed upon how and where used antifreeze can be disposed of, it is imperative that generators have convenient and economical recycling opportunities available. Failure to provide such opportunities may lead to improper disposal and possible enforcement action against the generator.
24.4.5 Establish a Used Anti-Freeze Diversion Goal
It is the goal of the DCCSWMP to divert ten percent of all retail antifreeze sold within the RPA.
24.5 ALTERNATIVES
24.5.1 Restrict Disposal to only Permitted and Approved Facilities
By restricting used antifreeze disposal to only permitted and approved facilities, proper disposal, diversion and recycling opportunities will be available within the RPA. This will ensure that the used antifreeze will be collected and disposed of at facilities which are operated in a manner which protects the public health and safety and the environment. All collection and disposal facilities would be required to conform to all federal, state and local regulations.
24.5.2 Encourage Retailers to Implement Take-Back Programs
Retailers who sell antifreeze, of all types, should be encouraged to implement a take-back program. This would allow the customer a convenient opportunity to dispose of the used antifreeze properly and at no or at minimum costs. The DCSWPO could provide technical assistance to businesses that choose to implement a take-back program. The DCSWPO could assist the businesses by coordinating recycling options, by promoting the take-back programs, by offering workshops and similar assistance.
24.5.3 Encourage Businesses to Collect and Recycle Used Antifreeze
A limited number of automotive shops within the RPA have used antifreeze collection programs. All of these programs are limited to just their own fleet or to only their customers. The DCSWPO should provide technical assistance to businesses that in the course of their normal operation collection antifreeze, either from their own fleet or their customers. For those businesses that sell antifreeze they should be encourage to develop a used antifreeze take-back program. The DCSWPO should develop a program to assist these businesses to establish used antifreeze take-back programs whenever practical and cost effective.
24.5.4 Site and Permit a Used Antifreeze Collection Center within the City of Bridgeport
Bridgeport currently does not have a Used Antifreeze Collection Center (UACC), whereas the participating jurisdictions of Douglas County, Mansfield, Rock Island and Waterville do. The Bridgeport UACC would provide the residents of the City of Bridgeport and the Greater Bridgeport area with a convenient opportunity to recycle their used antifreeze. The UACC would also, once fully developed, provide the City of Bridgeport with an alternative source for antifreeze.
24.5.5 Conduct an Annual Used Antifreeze Collection Program for Unincorporated Douglas County Residences
Because of the rural nature of the RPA, the large volume of used antifreeze available from the agricultural community and the distance to travel to the UACC, Douglas County should conduct an annual used antifreeze collection program. This program would allow county residents an opportunity to have their used antifreeze collected annually. Douglas County is currently divided into three regions, with each region serviced by its own shop and road crew. Under this alternative, each region would conduct an annual used antifreeze collection program for the residents within their specific geographic area. Each regional shop would notify the DCSWPO when they wished to hold their annual used antifreeze collection program. The DCSWPO would than promote the collection program and pre-register the participants. Once the pre-registration period ended, the DCSWPO would put together a collection schedule and provide reporting forms to the regional shop supervisor. Each regional shop would then implement the used antifreeze collection schedule. Prior to collection of the used antifreeze, the regional shop personnel would inspect the used antifreeze to see if it is usable and not contaminated. If the used antifreeze is acceptable, the county would collect the used antifreeze and transport it to the county UACC in Waterville. If the used antifreeze is rejected by the county, it will be up to the resident to properly dispose of their contaminated used antifreeze.
24.5.6 Collect Used Antifreeze at Used Antifreeze Collection Centers
Do-it-yourselfers should be encouraged to utilize the UACCs. The DCSWPO should develop a promotional program for these centers and inform the public about the benefits associated with their involvement in the program. Once the UACCs become established and the public becomes familiar with their purpose, hours of operation and antifreeze specifications, they should provide the cornerstone of the RPA used antifreeze management program. The successful utilization of the program by do-it-yourselfers will also assure the participating jurisdictions of a source of refurbished usable antifreeze at a reduced cost. By utilizing the refurbished antifreeze, the participating jurisdictions can off-set any costs associated with their collection program as well as reduce the cost of purchasing new antifreeze at a higher cost. All operating and maintenance costs associated with the UACCs, other than the reporting forms, are borne by the participating jurisdictions. All used antifreeze reporting forms are provided by the DCSWPO.
24.5.7 Develop a Point-of-Sale Notification Program for Antifreeze Retailers
A point-of-sale notification program should be implemented to determine the quantity and type of antifreeze purchased annually within the RPA. The program would be divided into four elements:
- a public education element,
- a data collection and reporting element,
- an antifreeze retail notification element,
- an annual program review element.
The public education element should be developed by the DCSWPO in conjunction with the business community. The data collection and reporting element should monitor all retail sales of antifreeze within the RPA to establish a baseline to help determine how effective the used antifreeze collection, diversion and recycling program is. The antifreeze retail notification element would require antifreeze retailers to report annually to the DCSWPO on how much antifreeze and what type of antifreeze they had sold within the reporting year. Also, as part of the antifreeze retail notification element, retailers would be required to post a public notice notifying its customers about how used antifreeze is to be disposed of and where they may dispose of their used antifreeze. The notice should be prominently displayed in the immediate proximity of where customers would find the antifreeze to purchase. Lastly, the participating jurisdictions should meet with the Douglas County Solid Waste Advisory Committee (SWAC) annually to review the effectiveness of the point-of-sale notification program. During this annual review, the following program points will be discussed:
- effectiveness of the public education program. Suggestions for improving the public education program,
- effectiveness of the data collection and reporting program. Suggestions for improving the data collection and reporting program,
- retail compliance with the antifreeze retail notification program. Suggestion for improving the antifreeze retail notification program,
- evaluation of the overall program and its effect upon retailers. This evaluation should be based upon the following:
a. effectiveness of the public education program upon the retailers,
b. burden placed upon the retailers to comply with the data collection and reporting program,
c. burden placed upon the retailers to comply with the antifreeze retail notification program,
d. effectiveness in determining the quantity and type of antifreeze purchased within the RPA.
24.5.8 Develop a Used Antifreeze Education Program
The DCSWPO should develop a used antifreeze education program. This program would specifically target do-it-yourselfers, automotive businesses and farmers with the requirements, methods and options available to them to properly manage their used antifreeze. The program could provide information on what is used antifreeze, how it is regulated, how to prevent contamination, how and where it can be disposed of, and similar information. The DCSWPO should develop brochures and information sheets to educate the public, generators and regulatory authorities about how used antifreeze is to be managed properly.
24.5.9 Monitor and Track Used Antifreeze
The DCSWPO needs to monitor and track all used antifreeze to determine who is generating the used antifreeze, the volume of used antifreeze being generated, where it originated from, where it is being disposed of, and how it is being disposed of. Without knowing these basic facts, it is impossible to properly manage the solid waste stream within the RPA. Therefore, the DCSWPO should establish a data tracking program that monitors and tracks all used antifreeze sold and disposed of within the RPA annually.
24.6 RECOMMENDATIONS
24.6.1 Restrict Disposal to Only Permitted and Approved Facilities
24.6.2 Encourage Retailers to Implement Take-Back Programs
24.6.3 Site and Permit a Used Antifreeze Collection Center within the City of Bridgeport
24.6.4 Collect Used Antifreeze at Community Used Antifreeze Collection Centers
24.6.5 Implement an Used Antifreeze Education Program
24.6.6 Monitor and Track Used Antifreeze