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 other non-vehicular coolants. However, to remove any ambiguity, EPA is revising the
engine coolant designation to specify that it applies to vehicles only.
b. Scope of designation. Two commenters urged EPA to limit the designation to
ethylene-glycol based engine coolants and exclude other types of engine coolants. These two
commenters stated that propylene glycol is not currently being reclaimed and that, therefore,
propylene glycol-based engine coolants do not meet the statutory requirements for
designation. Furthermore, one commenter noted that U.S. automobile manufacturers
`currently disallow the use of propylene glycol engine coolants in their products. Products
which are. not ethylene glycol-based fail to meet the appropriate chemical properties
requirement and are therefore not qualified for use in American Automobile Manufacturers
Association members' vehicles.'
EPA believes that propylene glycol-based engine coolants are not currently being
recovered and processed into reclaimed engine coolants. However, EPA is unaware of any
technical reason that would prevent this from occurring. RCRA directs EPA to "designate
those items which are or can be produced with recovered materials and whose procurement
by procuring agencies will carry out the objectives of this section [Section 6002 of RCRA]."
Rather than precluding procuring agencies from purchasing propylene glycol-based engine
coolants and reclaiming them, EPA concludes that it is inappropriate to limit the item
designation to ethylene glycol-based engine coolants only. If propylene glycol-based engine
coolants do not meet a procuring agency's performance requirements, the agency need not
purchase them. Thus, EPA has decided to finalize the engine coolants designation as
Proposed.
c. Hazardous waste. determination. Many comments stated that EPA should not
determine that spent engine coolants are hazardous wastes. Commenters also stated that their
spent engine coolants do not exhibit the toxicity characteristic of a hazardous waste.
The preamble to the proposed CPG included a statement that spent engine coolants in
some instances exhibit the toxicity characteristic of a hazardous waste. This was simply a
statement of fact and was not meant to imply that EPA believed that all spent engine coolants
exhibited the toxicity characteristic of a hazardous waste or that EPA was considering listing
spent engine coolants as a hazardous waste. EPA included these statements only for the
purpose of advising procuring agents that engine coolants can sometimes exhibit a
characteristic of a hazardous waste and, if disposed, must be disposed in accordance with
applicable state and Federal hazardous waste regulations.
d. Scope of ASTM test methods. Commenters pointed out that EPA stated incorrectly
in the preamble to the proposed CPG (see 59 18867, April 20, 1994) that American Society
for Testing and Materials (ASTM) tests D 3306 and D 4985 ate applicable to reclaimed
engine coolant. Commenters explained that these tests actually apply to new or virgin engine
coolant.
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