1 MN auto mercury switch programs History and current status John Gilkeson MN Pollution Control Agency January 18, 2006

2 MN auto switch history 6/92: MN passes first mercury product labeling law; autos exempted based on industry assurances that mercury is not an issue 6/93: Legislature funds Auto Shredder Residue (ASR) and Salvage Yard (SY) studies 9/93: UW-like framework established for lamps, elemental and amalgam mercury wastes 1994: ASR/SY studies find significant mercury switch use in autos; mercury in ASR

3 MN History continued 1995: MPCA proposes, Legislature enacts ‘good faith effort prior to crushing’ auto mercury switch removal requirement effective 8/1/ : MI and MN engage SAE and AAMA in switch discussions/white paper; first public estimate of 13 million switches, 10 tons of mercury (0.8 g/switch) used annually (or was it really 16 t/yr at 1.2 g/switch as determined by NJ studies in 2004?) Both states write letters requesting rapid phaseout of all auto mercury components and criticizing proposed approach for industry self-regulation

4 MN Salvage Yard Program to 2001: MN Legislature funds and MPCA operates Salvage Yard education and outreach program. Includes development of BMP manual, training, technical assistance. Includes BMPs & training on mercury switch identification, removal, and management MPCA enforces switch removal law MPCA provides free postpaid switch pellet recycling containers to yards ; no data on usage by yards.

5 MN EAF switch collection : Based on ASR/SY studies, MPCA urges state’s lone EAF to collect switches from suppliers as a service and manage under the UW-like framework 1997: Auto shredder/EAF starts accepting separated mercury switches from yards at no cost; few yards participate 1999: EAF starts paying $10/lb of switches; result is more switches from the same yards 2000: Increased to $40/lb of switches; result is more switches from more yards EAF estimates ~15-20% of suppliers participate in their switch collection program (may be higher now)

6 EAF Mercury Mass Balance EAF Facility Mercury Mass Balance (part of EAF Voluntary Reduction Agreement) [~ 11 lb/yr mercury collected in switches] ~136 lb/yr mercury input from autos/appliances ~290 lb/yr mercury input from other scrap ~ 11 lb/yr air emissions from shredder (2.6%) ~131 lb/yr air emissions from EAF (30.7%) ~ 77 lb/yr in Auto Shredder Residue (18%) ~207 lb/yr in EAF baghouse flue dust (48.6%) (1998 throughput, adapted from 12/28/99 Report)

7 State, County, EAF want more How to increase switch recovery at each yard? How to increase number of yards participating in switch recovery? How to increase compliance? (regulatory) How to provide incentives? (non-regulatory) How to mark vehicles to track inspection and removal from yard to crusher to shredder? How to get data on switch uses, recovery rates?

8 Voilá - Ramsey Pilot Project Eleven salvage yards, county RCRA inspector $1 bounty; base from NSS, the rest from PCA Tracking log: make/model/year/VIN/switches Vehicle marking protocol (front/rear fender) N: no switch found S: switch found S slashed: switch removed Monthly switch collection; transported in state vehicle to recycling facility; 6 month project

9 Findings, Results (2002 study) Recovery rate definitely increased ~8700 switches (~8.7 kg mercury) recovered from an estimated 14,000 vehicles, most from two yards with crushers 3300 vehicle sample: –58.5 switches/100 vehicles; –17% hood only; 5.6% trunk only; 18% hood and trunk (40.6/100 vehicles) Some newer mercury switches have a green housing - who did this, when, why? Corroded, leaking, empty switches – YES

10 Findings, Results (2002 study) Most vehicles were model year, few were newer than 1995 Few vehicles with ABS found-too new & valuable Most Big 3 model lines have at least one standard or optional mercury switch Few imports have switches, exceptions are Audi, J/US Mazda, US Nissan, Volvo (& MB?) (Audi/Volvo, old US have glass switches) (no info on Subarus/few in sample) OE/aftermarket security and remote starting systems have mercury switches

present 2004: Legislation introduced for mfr-funded program with incentive State-run program passes Senate Env. Committee AAM commits to funding ‘full’ education, collection, transportation, recycling program House Committee sets deadline for agreement AAM funds two year program operated by MN Waste Wise, nonprofit arm of MN Chamber of Commerce (total funding $150,000)

12 AAM Program in MN Funded June 2004, kickoff to yards Sept AAM agrees to pay for removal of pellets from assemblies and for all backlog switches Stored/shipped in three gallon buckets that hold ~150 assemblies, shipped by common carrier from/to MN consolidation facility, buckets are reused if possible; very little ‘junk’ sent in Most yards have been removing/storing switches since end of MPCA SY program in 2001

13 AAM Program issues (MN) It’s difficult to locate good lists of salvage yards and scrap processors, many sources used Data and tracking problems: assemblies are counted, but few if any yards are providing total vehicle count or specific vehicle data No ‘retired vehicle title’ data to help us track total vehicles or specific vehicle data We need some of this data to determine the per vehicle recovery rate and program capture rate.

14 AAM Program results (MN) May 2005 Implementation Progress Report: 346 yards likely handling switches out of potential 627 identified and 414 in business 85 of 320 yards contacted are recovering switches through other programs (26.6%) 174 out of 320 yards are removing switches, committed/interested (54.4%) 35 out of 320 yards are not removing switches, committed/interested (11%) 26 out of 320 unsure/refuse (8%)

15 AAM Program Results (MN) May 2005 Implementation Progress Report: 259 out of 320 yards already pulling switches when first contacted for AAM Program (80%) due to 7-10 year history of programs in state 20,600 switches collected by May 4, 2005; this includes both backlog and new removals January 2006: We do not yet have data/estimates on total vehicles processed, total switch recovery, per vehicle recovery rate, or program capture rate for the AAM Program